U.S. Partnerships With Foreign Partners: Navigating Withholding, Informational Reporting and Payment Requirements
Determining ECI, FDAP, FIRPTA Income Classifications, Treaty Benefits, Basis Adjustments and Sale Treatment
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers and compliance professionals with a thorough and practical guide to the issues faced by U.S. partnerships with foreign partners. The panel will discuss the various withholding requirements for non-U.S. partners, treaty structures (including limitation on benefits provisions), and often overlooked capital account adjustments particular to foreign partners.
Outline
- Income taxation of partnerships with foreign partners
- Blocker corporations and foreign partnerships
- Partnership Chapter 3 withholding and reporting
- Partnership Chapter 4 (FATCA) withholding and reporting
- TCJA changes to withholding calculations
- Filing requirements
Benefits
The panel will discuss these and other important issues:
- Documentation partnerships must obtain from foreign partners and associated reporting to the IRS
- Withholding requirements for effectively-connected income for foreign partners
- Withholding requirements for FDAP, FIRPTA and other non-business partnership income
- Use of blocker corporations and other intermediate entities
- Impact of treaty positions on income taxes and withholding
- Filing requirements
Faculty

Alfred H. Bae
Ernst & Young

Rita M. Ryan
Atty
Vacovec Mayotte & Singer
Ms. Ryan practices in the areas of international and domestic taxation, estate planning, and tax controversy.... | Read More
Ms. Ryan practices in the areas of international and domestic taxation, estate planning, and tax controversy. Prior to joining the firm, she was with PricewaterhouseCooper’s National Tax Services, Exempt Organization Tax Services group. While at PwC, she provided specialized tax consulting and compliance services to non-profit organizations including higher education institutes, foundations, and health care systems. Prior to her tenure at PwC, she served as an Appeals Officer with the Massachusetts Department of Revenue, Office of Appeals, where she heard and issued letters of determination with regard to corporate, individual, and estate tax matters.
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Arthur R. Kerr, II
Partner
Vacovec Mayotte & Singer
Mr. Kerr concentrates his practice in international and domestic taxation, business law, contracts, and real estate.... | Read More
Mr. Kerr concentrates his practice in international and domestic taxation, business law, contracts, and real estate. His tax practice includes offshore and onshore planning and compliance for businesses and individuals, civil and criminal examinations and audits, collection matters, workouts, and tax controversies. Mr. Kerr extensive experience representing clients before the Internal Revenue Service and various state tax authorities.
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