FMN Plus-2024/Jan, Seg 1 - Section 1446(f) PTP Withholding Tax: Proficiency & Purpose
Before passing of the Tax Cuts and Jobs Act (TCJA) in 2017, taxation on the sale of a partnership interest by a foreign person was not clearly defined. Section 1446(f) of the Internal Revenue Code, imposed a 10% withholding tax on the amount realized from a foreign person’s sale, exchange, or other disposition of a partnership interest to the extent the foreign person would have effectively connected income (ECI) under Section 864(c)(8). Seth Poloner, Executive Director at Morgan Stanley, joins this segment to discuss the importance of Section 1446(f), custodial broker requirements, exceptions to Section 1446(f), and an update on Notice 2023-8.
Learning Objectives:
Upon successful completion of this segment, attendees should be able to:
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Upon successful completion of this segment, attendees should be able to:
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Recognize the impact of Notice 2023-8 on PTPs, short sales, and retroactive forms
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Identify the various IRC Section 1446(f) exceptions related to Form W-9, QIs, non-withholding foreign partnerships, and qualified notices
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Distinguish between both custodial and executing brokers involved PTP transactions
- Describe both the history and significance of IRC Section 1446(f)
Prerequisites/Advanced Preparation:
None
Details
Course Code
:
FMN1542-FM
Release Date
:
01/10/2024
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Expire Date
:
08/13/2025
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Credits
:
|
Length
:
1hr 40min
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Course Level
:
Update
|
Course Type
:
QAS Self-Study
|
Passing Grade
:
70%
|
Format Type
:
eLearning
Mobile Compatible
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Field Of Study
:
Taxes
|
|
Theme
:
Corporate Tax Series
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