Foreign Pension Funds And Your Partnership

Exemption from FIRPTA Withholding and Tax under IRC §897 for Qualified Foreign Pension Funds Not Applicable to IRC §1446 Qualified foreign pension funds are not exempt from U.S. withholding tax on foreign partners’ share of U.S. effectively connected income. As discussed in our March 1, 2016 blog post (Path-Act), the Protecting Americans from Tax Hikes…

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Are Partnership Business Structures On The Rise?

Partnership Business Structures Expected to Continue Tremendous Growth According to Clifford M. Warren, special counsel to the IRS associate chief counsel of Passthroughs and Special Industries, the IRS has seen tremendous growth in partnership business structures, including joint venture partnerships between large corporations and startups, managed-fund partnerships, energy partnerships, financial services partnerships and publicly-traded partnerships.…

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Proposed Legislation Could Mean A Tax Break For You

Proposed congressional legislation would create tax parity among pass-through and corporate income tax rates. Rep. Vern Buchanan (R-FL) has recently introduced the Main Street Fairness Act which would link the top marginal tax rate paid on pass-through business income to the corporate tax rate. Buchanan is a senior member of the tax-writing House Ways and…

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