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 course 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 and reporting requirements with respect to non-U.S. 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
- IRC Section 1446(f) withholding requirements
- Filing requirements
Benefits
The panel will discuss these and other important issues:
- Documentation partnerships must obtain from foreign partners
- Withholding requirements for effectively-connected income for foreign partners under Section 1446
- Withholding requirements for FDAP income under Chapter 3 and 4, including the impact of treaty positions on these obligations
- Withholding requirements under FIRPTA and Section 1446(f) upon transfers of partnership interests
- Impact of blocker corporations and other intermediate entities
- Filing requirements
Faculty

Joshua S. Kaplan
Managing Director
KPMG US
Mr. Kaplan provides advice on a wide range of inbound and outbound international tax issues, with a particular focus on... | Read More
Mr. Kaplan provides advice on a wide range of inbound and outbound international tax issues, with a particular focus on inbound investment, including FIRPTA, section 892, branch profits tax, U.S. trade or business and effectively connected income (“ECI”) determinations, treaty qualification and permanent establishment issue, sales of ECI partnerships by foreign persons, and chapter 3 withholding. He routinely advises clients on buy-side and sell-side FIRPTA due diligence issues, FIRPTA withholding and reporting requirements, tax-efficient structuring for funds and REITS with foreign investors, and the application of the FIRPTA nonrecognition rules to corporate formation, restructuring, and divestiture transactions. Josh also has significant experience with U.S. real property holding corporation determinations, particularly in the power generation, electric transmission and distribution, and telecommunications industries.
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Danielle Nishida
Principal, Information Reporting & Withholding Tax
KPMG US
Ms. Nishida joined KPMG in April 2013 and practices in information reporting. She was previously an attorney in the... | Read More
Ms. Nishida joined KPMG in April 2013 and practices in information reporting. She was previously an attorney in the Office of Chief Counsel (International) at the Internal Revenue Service (IRS). At the IRS, she practiced in income tax withholding and Subpart F, and was a principal draftsperson of the FATCA regulations, the pending proposed chapter 3 and 61 conforming regulations, and other published guidance under sections 1441, 1442, 1471 through 1474, and 6050W. Ms. Nishida is a frequent speaker both in the U.S. and internationally regarding FATCA and other information reporting issues.
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