Page 226 - International Taxation IRS Training Guides

Foreign Partner with

US Trade or Business (Cont’d)

that a nonresident alien individual’s or
 TCJA provides
gain or loss from the sale of a
foreign corporation’s

effectively connected with a US trade
partnership interest is
or
business to the extent that the sale of the underlying
at fair market value on the date of the exchange
assets

would have resulted in effectively
connected income for the
foreign partner

• Effective for
sales, exchanges, or other dispositions occurring on or
after Nov. 27, 2017

 TCJA also enacts a 10% withholding tax on the amount

realized under new IRC 1446(f)

sales, exchanges, or other dispositions occurring after
• Effective for
December 31, 2017

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