Your videos are always great. I have a client who is a partnership with foreign and domestic partners that invest in non-US corporations and wasn't very familiar with Forms 8804 or 8805. This made everything crystal clear.
what if the person is a non usa person but has an llc already in the usa and wants to be a member in another person's LLC, SINCE he wants to be a partner with them. is it possible?
Yes, a multi-member LLC can have both U.S. & non-U.S. partners. However, if the US LLC is engaged in US trade or business and has ECI, the income allocation to the nonresident partner will likely be subject to withholding taxes. It's important for the LLC and both owners to carefully assess the tax impact of becoming partners in the business.
I have a tax payer that received 1 k1 that has ECI and 1 K1 that does not have ECI. How can I file the tax return - without having to pay taxes of the 2nd K1 with no ECI? Thanks ahead for your answer.
Thank you for sharing this helpful video. Do we still hold the 21% withholding tax rate for Canadian partner in partnership or less due to the US - Canada tax treaty?
I have a DE partnership with 2 foreign owners. The only asset is a brokerage account which generated dividend and interest income. In preparing the form 1065, I have net income of $XXX (dividends + interest-expenses). In preparing Form 8804, is this FDAP income subject to withholding?
Your videos are always great. I have a client who is a partnership with foreign and domestic partners that invest in non-US corporations and wasn't very familiar with Forms 8804 or 8805. This made everything crystal clear.
Glad it was helpful. Thanks for watching!
what if the person is a non usa person but has an llc already in the usa and wants to be a member in another person's LLC, SINCE he wants to be a partner with them. is it possible?
Yes, a multi-member LLC can have both U.S. & non-U.S. partners. However, if the US LLC is engaged in US trade or business and has ECI, the income allocation to the nonresident partner will likely be subject to withholding taxes. It's important for the LLC and both owners to carefully assess the tax impact of becoming partners in the business.
I have a tax payer that received 1 k1 that has ECI and 1 K1 that does not have ECI. How can I file the tax return - without having to pay taxes of the 2nd K1 with no ECI? Thanks ahead for your answer.
Thank you for sharing this helpful video. Do we still hold the 21% withholding tax rate for Canadian partner in partnership or less due to the US - Canada tax treaty?
I have a DE partnership with 2 foreign owners. The only asset is a brokerage account which generated dividend and interest income. In preparing the form 1065, I have net income of $XXX (dividends + interest-expenses). In preparing Form 8804, is this FDAP income subject to withholding?
i want to open llc with my father..he is u.s resident but i am not...how should we create and whats requiremnts?
What if the foreign corporation that wants to partner with my llc has as its main owner a foreigner who has US residency? She lives in the US
May I have a LLC company which do business in US at 21% tax (real estate) and, at the same time, do business at stock exchange 0% tax?