合作伙伴关系 and Investors

There are domestic (US) partnerships and foreign (non-US) partnerships. A domestic partnership must file an annual tax return to report the income, 扣除, 收益, 损失, 等., from its operations, but it does not pay 所得税. 而不是, it “passes through” profits or 损失 to its partners (个人s, 公司, 信托基金, 等.)，填妥K-1表格. Private equity and venture capital funds will often be structured as a limited partnership.

A US person who receives a Schedule K-1 that reports income from a partnership, or who otherwise has income from a foreign partnership is subject to US taxation on such income.  This applies to Limited Partners in an investment fund as well.  If a foreign partnership has ECI (effectively connected income) that is allocated to a non-US partner, the partnership is required to report and pay a withholding tax to the IRS.  

As is the case with 基金, 外国企业, operating as partnerships, with US operations generally must file a US partnership return of income and non-US partners may be required to file US non-resident 所得税 returns in the case of individuals or a US Income Tax Return of a Foreign Corporation if the partner is a corporation.  Non-US partnerships with US partners or US connections may also have complicated US reporting requirements even with no US operations.

Our Advisory 服务

• US tax planning for US and non-US investors of partnerships
• Allocations of partnership income, 损失 and 扣除 according to substantial economic effect
• 新法 & CRS报告
• 预扣税

Our Compliance 服务

Under the US tax system, domestic and foreign partnerships have complex reporting requirements for the Partnership itself and for its Partners or Investors.  These include reporting the partnership allocations to the partners through K-1s or determining withholding taxes.

Integrated Partnership and Investor Experts

合作伙伴关系, both domestic and non-US, have unique characteristics and require expertise across several areas including 基金, 公司, 信托基金 and 私人客户.  We coordinate all aspects of Partnership reporting along with the related Investor reporting, through to the analysis of an 个人’s or Entity’s specific position.

澳门官方老葡京 to discuss how we can help.