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Discussion:Partnership W/H on effectively connected income

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Discussion Forum Index --> Advanced Tax Questions --> Partnership W/H on effectively connected income


Discussion Forum Index --> Tax Questions --> Partnership W/H on effectively connected income

Jwebbb (talk|edits) said:

2 April 2014
Hi there.

Anyone out there have any experience with a Russian national foreign partner of a US domestic partnership (LLC) on tax supposed to be withheld from his allocation of effectively connected taxable income? The instructions say the tax rate is 39.6% but refers to possible tax treaty benefits for a rate reduction. I looked at the US - Russia tax treaty of 1992 and found nothing about a rate reduction but in Article 20 that "a person that is a resident of a Contracting State and derives income from he other Contracting State shall be entitled under this Convention to relief from taxation in that other State only if such person is (a) an individual , etc. etc." That would appear to me to mean no withholding is required but I know that can't be true.

This is an issue I really cannot spend huge amounts of time to research during the height of tax season. A quick answer and source referral would be much appreciated.

Julian

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