My U.S. partnership has a foreign partner. Do we need to file Form 8804 for withholding?
I run a U.S. LLC taxed as a partnership with two partners — myself (a U.S. citizen) and a partner who lives in Germany and is not a U.S. person. The partnership earned about $200,000 in effectively connected income last year. My accountant says we need to withhold tax on the German partner's share and file Form 8804. How does this work exactly? The German partner's share was about $100,000 but we didn't distribute all of it.
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