What is Section 1446 withholding and how does it apply to foreign LLC members?
I am a foreign partner in a multi-member LLC that is treated as a partnership for U.S. tax purposes. I was told that the LLC must withhold tax on my share of the partnership's effectively connected income under Section 1446. How does this withholding work? What rate applies, and how does it interact with my actual tax liability when I file my U.S. return?
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