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Wednesday, July 24  |  1:15 p.m. - 2:05 p.m.  |  Concurrent Session

Taxation of U.S. Partnerships with Foreign Partners

2 CPE for AFSP, EA, CFP®, CPA, CRTP    

This course will teach attendees what has to happen within the partnership when one or more partners are foreign partners, including what documents are needed from a foreign partner and withholding requirements under §1446. Additionally, we will address the filing requirements for a partnership with a foreign partner.   

Upon completion of this session, you will be able to:

  • Outline what documentation partnerships must obtain from foreign partners 

  • Summarize the withholding requirements for effectively connected income of foreign partners under §1446 

  • Identify the withholding requirements for FDAP income under Chapters 3 and 4, including the impact of treaty positions on these obligations  

  • Determine the withholding requirements under FIRPTA and §1446(f) upon transfers of partnership interests 

  • Summarize the impact of blocker corporations and other intermediate entities 

  • Interpret the partnership’s filing requirements 

CPE information
Duration: 100 minutes
Course level: Advanced
Prerequisite: Strong understanding of partnership taxation
Advanced preparation: None
Delivery method: Group Live

Jeffrey Schneider

Executive VP at SFS Tax & Accounting

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