• videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Gain on Sales of U.S. Partnership Interests by Foreign Partners: Sections 864(c)(8) and 1446(f)

Determining and Reporting Gain on Effectively-Connected U.S. Source Income

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
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About the Course

Introduction

This CLE/CPE course will provide tax counsel and advisers with a critical look at sales of U.S. partnership interests by foreign partners under current tax law. The panel will discuss new and significant changes to international taxation relating to the disposition of U.S. partnership interests owned by foreign partners and taxpayers, recognized taxable gain, and available planning techniques.

Description

Tax reform ushered in significant changes to international taxation, including a provision that supersedes the Tax Court's decision in Grecian Magnesite with amended Sections 864(c)(8) and 1446(f). Tax counsel and advisers must navigate the filing requirements under current tax law and implement effective planning techniques to limit tax liability upon foreign persons' disposition of U.S. partnership interests.

The sale, exchange, or other disposition of a partnership interest held by foreign persons may trigger the withholding and filing requirements under Sections 864(c)(8) and 1446(f). Under current tax law, dispositions of partnership interests by foreign owners include all partnership assets that are effectively connected to a U.S. trade or business. Section 864(c)(8) of the Internal Revenue Code provides that effectively-connected income (ECI) includes the gain or loss on the sale of an interest in a partnership engaged in a U.S. trade or business.

Section 1446(f) provides that if any gain from a sale or exchange of an interest in a partnership is treated under Section 864(c)(8) as effectively connected with the conduct of a trade or business within the U.S., then the transferee must collect a 10 percent withholding tax from any seller of a partnership interest. If the buyer fails to withhold any amount required under Section 1446(f), the issuer partnership is liable for the unpaid withholding tax.

Listen as our experienced panel critically examines the structuring and reporting impacts of the new tax law provisions on non-U.S. persons holding U.S. partnership interests.

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • CPE credit is not available on recordings.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Wednesday, July 20, 2022

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Determining ECI under current tax law
  2. Section 1446(f); calculating the amount realized on the disposition of a partnership interest
  3. Remedial actions and tactics for non-U.S. partners paying tax on partnership sale gain
  4. Impact on existing partnership structures

The panel will review these and other critical issues:

  • What actions should counsel recommend to a non-U.S. partner from selling a U.S. partnership based on an ECI determination?
  • What is the impact of the tax rules on domestic and foreign blocker corporations investing in U.S. partnerships?
  • What are the methods of determining the source and calculating ECI of partnership sale gain amounts?
  • What should tax counsel consider for existing partnership structures under current tax law?

Learning Objectives

After completing this course, you will be able to:

  • Recognize the impact on non-U.S. persons using foreign blocker corporations to hold U.S. partnership interests
  • Identify non-U.S. persons who may be adversely affected by Sections 864(c)(8) and 1446(f)
  • Determine steps tax counsel and advisers should take for both existing partnership structures and for non-U.S. persons who have reported taxable gain or loss from the sale of U.S. partnership interests
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business, law or public firm experience at mid-level within the organization, overseeing and structuring U.S. taxpayers' transactions involving foreign partnerships and vice versa; supervisory authority over other attorneys, preparers/accountants. Knowledge and understanding of tax recognition standards for U.S.-sourced and effectively connected income; familiarity with U.S. and foreign partnership structures.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .