BNA - FIRPTA - Understanding U.S. Taxation of Foreign ...
• 1445(e)(3) – Distribution by USRPHC to foreign shareholders if a redemption under section 302 or liquidating distribution (or 301 distribution that is not a dividend) – withholding on 10% of the amount realized by the foreign shareholder. • 1445(e)(4) – Taxable Distributions by Domestic or Foreign Partnerships.
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