Section 1446(f) US Tax Regulations relating to withholding tax on U.S. Public Traded Partnership
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Section 1446(f) US Tax Regulations relating to withholding tax on U.S. Public Traded Partnership
The U.S. Internal Revenue Service (IRS) has released the latest regulations on withholding tax in relation to interests in public traded partnerships (including Exchange Traded Funds which are partnerships) (“PTPs”). The upcoming section 1446(f) of the U.S. Internal Revenue Code will take effect on 1 January 2023. It imposes new withholding and reporting requirements on the transfer of interests in PTPs by non-U.S. persons.
If client’s account is holding securities in scope for section 1446(f), such securities may be subject to new or increased U.S. withholding tax, including a 10% withholding tax on distributions and 10% withholding tax on gross proceeds from the sale of PTPs.
If client’s account is holding securities in scope for section 1446(f), such securities may be subject to new or increased U.S. withholding tax, including a 10% withholding tax on distributions and 10% withholding tax on gross proceeds from the sale of PTPs.