TDA101696
TDA101696
TDA101696
publicly traded
partnerships held by
foreign persons
The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have introduced new regulations under Internal
Revenue Code, Section 1446(f) regarding publicly traded partnership (PTP) securities held by foreign persons (individuals or
entities). The withholding requirements under the new regulations will go into effect on January 1, 2023 and could impact clients
in the following ways:
• Beginning on January 1, 2023 we will withhold 10% of gross proceeds from sales of PTP securities and certain distributions by PTPs.
• The transactions and related withholding tax will also be reported on Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding.
• This new PTP withholding tax is separate from the existing 37% withholding for individuals and 21% withholding for entity accounts on
payments of U.S. source income related to PTP securities.
• For more detail regarding Section 1446(f) regulations, please review the information available online on the IRS website:
www.irs.gov/individuals/international-taxpayers/partnership-withholding.
Investment Products: Not FDIC Insured * No Bank Guarantee * May Lose Value