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- Re: How do I suppress forms 8804/8805 when my partnership has no US source income? All operations are conducted outside of the US?
How do I suppress forms 8804/8805 when my partnership has no US source income? All operations are conducted outside of the US?
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christine.balla
Level 1
09-10-2020
05:08 PM
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1 Comment 1
itonewbie
Level 15
09-10-2020
10:57 PM
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partnership has no US source income? All operations are conducted outside of the US?
Probably more question to ask your client... I'd probably ask my client what the purpose of setting up a US partnership is and how the transactions are structured before drawing a conclusion.
By virtue of setting up a US partnership, your client has a US office/fixed place of business for domestic tax and treaty purposes. This is an important consideration for purposes of determining whether there is any ECI pursuant to §1.1446-2, even if the operations are conducted outside the US, especially with respect to §864.
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