U.S. Income Tax Compliance
U.S. Income Tax Compliance
U.S. Income Tax Compliance
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When is a foreign partner required to file a return?<br />
• General rule – every nonresident alien individual and<br />
foreign corporation is required to file a U.S. income tax<br />
return if<br />
– They have U.S. source income the tax on which is not fully<br />
satisfied by withholding<br />
– They are engaged in a U.S. trade or business at any time during<br />
the taxable year<br />
• Even if no ECI<br />
• Even if no U.S. source income<br />
• Even if all income is exempt under a treaty<br />
• Section 875(1) provides that if a partnership is engaged<br />
in a U.S. business, its foreign partners are deemed to be<br />
engaged in such business
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