What is IRC 1446 withholding on foreign partners and why is the U.S. partnership withholding from my share?
I'm a German citizen who is a 40% partner in a U.S. LLC taxed as a partnership. The partnership operates a restaurant in New York. The managing partner told me the partnership has to withhold tax from my share of the profits under IRC 1446. I thought partnerships didn't pay tax — the income just passes through. Why is the partnership withholding from my distributions?
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