Become familiar with the requirement to make withholding tax payments.
If a domestic partnership has foreign partners that have been allocated effectively connected income, they will need to file forms 8804, 8805, and 8813 to report this income. The amount of ECTI allocable to a foreign partner includes the foreign partners’ distributive share of effectively connected gross income of the partnership for the partnership’s tax year less the foreign partner’s distributive share of deductions of the partnership for that year that are connected with that income and are properly allocated to the partner under 704. This video reviews the different forms that are required to be filed by a foreign partner and discusses the coordination with FDAP withholding rules.
Mike Burgess, J.D.
- Serves as a senior manager with Crowe LLP’s international tax group
- Has more than 20 years of experience in international tax including both compliance and planning for public and private companies
- Has a broad range of industry experience, including manufacturing and distribution, retail and technology, among others
- Throughout his career he has acquired extensive experience in international compliance issues including completion and review of all U.S. international tax forms
- Since 2010 he has focused on providing international tax services to publicly and privately held multinational companies in the middle market on a wide range of international tax issues, including, in addition to the above, structure planning, mergers and acquisition, cross-border transactions and Subpart F analysis, GILTI, FDII, BEAT, and foreign tax credits
- Prior to joining Crowe, he spent more than 10 years in Big 4 public accounting firms where he gained an extensive background in implementing global holding company structures designed to improve a company’s tax positions and efficiently manage cash through intercompany financing and cash planning
- Has specific experience in development and implementation of international structuring and restructuring projects
- J.D. degree, Lewis & Clark College
Danish N. Meherally, J.D., LL.M.
- Manager in the Atlanta office of Crowe LLP
- Practice emphasizes all aspects of international tax
- LL.M. degree in tax , University of Florida School of Law; J.D. degree, Ave Maria School of Law
- Can be contacted at [email protected]
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