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Instructions for Form 1042-S
taxmap/instr2/i1042s-009.htm#en_us_publink64278ad0e1395

taxmap/instr2/i1042s-009.htm#TXMP1c4b72de
Publicly Traded Partnerships (Section 1446 Withholding Tax)(p9)

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A publicly traded partnership (PTP) (defined earlier in Definitions) that has effectively connected income must pay a withholding tax under section 1446 on distributions of that income made to its foreign partners and file Form 1042-S using income code 27 and chapter 4 exemption code 14. A nominee that receives a distribution of effectively connected income from a PTP is treated as the withholding agent to the extent of the amount specified in the qualified notice received by the nominee. For this purpose, a nominee is a domestic person that holds an interest in a PTP on behalf of a foreign person. See Regulations section 1.1446-4 and Pub. 515 for details.
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If you are a nominee that is the withholding agent under section 1446, enter the PTP's name and other required information in boxes 15a through 15i on Form 1042-S.
Partnerships (other than publicly traded partnerships) that have effectively connected gross income allocable to foreign partners must file Form 8804, Annual Return for Partnership Withholding Tax (Section 1446). If these partnerships have effectively connected taxable income allocable to foreign partners, they must also pay a withholding tax under section 1446 and report these amounts on Form 8804 and the partners' allocable shares of these amounts on Form 8805, Foreign Partner's Information Statement of Section 1446 Withholding Tax.