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Home / Tolley's Global Mobility: Personal Taxes /USA /US1 Overview of the tax regime in the United States /US1.6 Withholding taxes / US1.6.5 Withholding on distributions from a US partnership to a foreign partner

US1.6.5 Withholding on distributions from a US partnership to a foreign partner

USA

Withholding under IRC Section §1446(a)–(d) comes into play when a US partnership generates income connected to a US trade or business ('effectively connected income' or 'ECI') and distributes an allocation of that to a partner who is not a US person. (eg a non-resident

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IR1.3.3 Other taxes in Ireland

IS2.6 Use of trust or other similar vehicle to assist in personal tax planning for wealth

IS2.5.5 Tax application and ramifications of marriage and divorce

IS2.7.1 Registration

IS2.8.4 Closing a small business

SG1.4.4 Inheritance tax

FR2.7.1 French matrimonial regimes

UK2.10.1 Tax reliefs for borrowing costs to expand a UK business

IS2.2 Taxation of rental income in Israel

CA2.4.2 Old Age Security (OAS) and Guaranteed Income Supplement (GIS)

SG3.2.6 Expiry and invalidity of a Power of Attorney (POA)

CA3.3 Local currency and currency restrictions

AU3.4.1 Excepted person

JE1.7 Social security

AU2.4.4 Undeducted purchase price (UPP)

IS1.4.2 Capital gains tax

SW1.3.3 Wealth tax

SG2.6.2 Prescribed locally administered trusts

CA3.1 How to obtain a Canadian residence certificate

SG2.6.4 Foreign trusts

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