Form 8804-C - Certificate of Partner-Level Items to Reduce Section 1446 Withholding

These previously approved regulations implement withholding regime on partnerships conducting business in the United States that have foreign partners. Such partners are required to pay withholding tax in installments on each foreign partner's allocable share of the partnership's U.S. Business taxable income. Special rules for publicly traded partnerships such that these partnerships pay withholding tax on distributions to foreign partners. Form 8804-C is used by a foreign partner who chooses to provide to a partnership a certification under Regulations section 1.1446-6 to reduce or eliminate the partnership's withholding tax obligation under section 1446 (1446 tax) on the partner's allocable share of effectively connected taxable income (ECTI) from the partnership.

The latest form for Form 8804-C - Certificate of Partner-Level Items to Reduce Section 1446 Withholding expires 2021-04-30 and can be found here.

TD 9394 - Special Rules To Reduce Section 1446

Federal Enterprise Architecture: General Government - Taxation Management