Thursday, March 27, 2008

Is there a tax on foreign investment in the US?

The IRS modified final withholding on foreign partnership and foreign trust agreements contained in Rev. Proc. 2003-64 by expanding availability of certain simplified documentation and withholding procedures. The IRS eliminated the requirement of a general partner and that the qualified intermediary withholding agreements, withholding partnership or withholding trust may apply simplified documentation, reporting and withholding procedures to a foreign trust or foreign partnership. The revenue procedure further provides that pursuant to Sec. 12.02 of the QI agreement, and Sec. 11.02 of the WP and WT agreements, these amendments will be incorporated.

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