Common use of Special rules for partnerships Clause in Contracts

Special rules for partnerships. Partnerships that conduct a trade or business in the United States are generally required to pay a withholding tax under section 1446 on any foreign partners’ share of effectively connected taxable income from such business. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner is a foreign person, and pay the section 1446 withholding tax. Therefore, if you are a U.S. person that is a partner in a partnership conducting a trade or business in the United States, provide Form W-9 to the partnership to establish your U.S. status and avoid section 1446 withholding on your share of partnership income. In the cases below, the following person must give Form W-9 to the partnership for purposes of establishing its U.S. status and avoiding withholding on its allocable share of net income from the partnership conducting a trade or business in the United States. • In the case of a disregarded entity with a U.S. owner, the U.S. owner of the disregarded entity and not the entity; • In the case of a granter trust with a U.S. granter or other U.S. owner, generally, the U.S. granter or other U.S. owner of the granter trust and not the trust; and • In the case of a U.S. trust (other than a granter trust), the U.S. trust (other than a granter trust) and not the beneficiaries of the trust.

Appears in 3 contracts

Samples: Merger Agreement (TPCO Holding Corp.), Merger Agreement (TPCO Holding Corp.), Merger Agreement (TPCO Holding Corp.)

AutoNDA by SimpleDocs

Special rules for partnerships. Partnerships that conduct a trade or business in the United States are generally required to pay a withholding tax under section 1446 on any foreign partners’ share of effectively connected taxable income from such business. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner is a foreign person, and pay the section 1446 withholding tax. Therefore, if you are a U.S. person that is a partner in a partnership conducting a trade or business in the United States, provide Form W-9 to the partnership to establish your U.S. status and avoid section 1446 withholding on your share of partnership income. In the cases below, the following person must give Form W-9 to the partnership for purposes of establishing its U.S. status and avoiding withholding on its allocable share of net income from the partnership conducting a trade or business in the United States. • In the case of a disregarded entity with a U.S. owner, the U.S. owner of the disregarded entity and not the entity; • In the case of a granter grantor trust with a U.S. granter grantor or other U.S. owner, generally, the U.S. granter grantor or other U.S. owner of the granter grantor trust and not the trust; and • In the case of a U.S. trust (other than a granter grantor trust), the U.S. trust (other than a granter grantor trust) and not the beneficiaries of the trust.

Appears in 3 contracts

Samples: Convertible Note Purchase Agreement (Ascend Wellness Holdings, LLC), Crescent Capital BDC, Inc., Exchange Agreement (Pluralsight, Inc.)

Special rules for partnerships. Partnerships that conduct a trade or business in the United States are generally required to pay a withholding tax under section 1446 on any foreign partners’ share of effectively connected taxable income from such business. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner is a foreign person, and pay the section 1446 withholding tax. Therefore, if you are a U.S. person that is a partner in a partnership conducting a trade or business in the United States, provide Form W-9 to the partnership to establish your U.S. status and avoid section 1446 withholding on your share of partnership income. In the cases below, the following person must give Form W-9 to the partnership for purposes of establishing its U.S. status and avoiding withholding on its allocable share of net income from the partnership conducting a trade or business in the United States. • : · In the case of a disregarded entity with a U.S. owner, the U.S. owner of the disregarded entity and not the entity; · In the case of a granter grantor trust with a U.S. granter grantor or other U.S. owner, generally, the U.S. granter grantor or other U.S. owner of the granter grantor trust and not the trust; and · In the case of a U.S. trust (other than a granter grantor trust), the U.S. trust (other than a granter grantor trust) and not the beneficiaries of the trust.

Appears in 3 contracts

Samples: Deposit Agreement (Citibank,N.A./ADR), The Deposit Agreement (Citibank,N.A./ADR), Deposit Agreement (Citibank,N.A./ADR)

Special rules for partnerships. Partnerships that conduct a trade or business in the United States are generally required to pay a withholding tax under section 1446 on any foreign partners’ share of effectively connected taxable income from such business. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner is a foreign person, and pay the section 1446 withholding tax. Therefore, if you are a U.S. person that is a partner in a partnership conducting a trade or business in the United States, provide Form W-9 to the partnership to establish your U.S. status and avoid section 1446 withholding on your share of partnership income. In the cases below, the following person must give Form W-9 to the partnership for purposes of establishing its U.S. status and avoiding withholding on its allocable share of net income from the partnership conducting a trade or business in the United States. • In the case of a disregarded entity with a U.S. owner, the U.S. owner own of the disregarded entity and not the entity; • In the case of a granter grantor trust with a U.S. granter grantor or other U.S. owner, generally, the U.S. granter grantor or other U.S. owner of the granter grantor trust and not the trust; and • In the case of a U.S. trust (other than a granter grantor trust), the U.S. trust (other than a granter grantor trust) and not the beneficiaries of the trust.

Appears in 1 contract

Samples: Loan and Security Agreement (Outbrain Inc.)

AutoNDA by SimpleDocs

Special rules for partnerships. Partnerships that conduct a trade or business in the United States are generally required to pay a withholding tax under section 1446 on any foreign partners' share of effectively connected taxable income from such business. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner partne. r is a foreign person, and pay the section 1446 withholding tax. Therefore, if you are a U.S. person that is a partner in a partnership conducting a trade or business in the United States, provide Form W-9 to the partnership to establish your U.S. status and avoid section 1446 withholding on your share of partnership income. In the cases below, the following person must give Form W-9 to the partnership for purposes of establishing its U.S. status and avoiding withholding on its allocable share of net income from the partnership conducting a trade or business in the United States. : • In the case of a disregarded entity with a U.S. owner, the U.S. owner of the disregarded entity e tity and not the entity; • In the case of a granter grantor trust with a U.S. granter grantor or other U.S. owner, generally, the U.S. granter grantor or other U.S. owner of the granter grantor trust and not the trust; and • In the case of a U.S. trust (other than a granter grantor trust), the U.S. trust (other than a granter grantor trust) and not the beneficiaries of the trust.

Appears in 1 contract

Samples: Agreement for Services

Special rules for partnerships. Partnerships that conduct a trade or business in the United States are generally required to pay a withholding tax under section 1446 on any foreign partners’ share of effectively connected taxable income from such business. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner is a foreign person, and pay the section 1446 withholding tax. Therefore, if you are I am a U.S. person that is a partner in a partnership conducting a trade or business in the United States, I must provide Form W-9 to the partnership to establish your my U.S. status and avoid section 1446 withholding on your my share of partnership income. In the cases below, the following person must give Form W-9 to the partnership for purposes of establishing its U.S. status and avoiding withholding on its allocable share of net income from the partnership conducting a trade or business in the United States. • In the case of a disregarded entity with a U.S. owner, the U.S. owner of the disregarded entity and not the entity; • In the case of a granter grantor trust with a U.S. granter grantor or other U.S. owner, generally, the U.S. granter grantor or other U.S. owner of the granter grantor trust and not the trust; and • In the case of a U.S. trust (other than a granter grantor trust), the U.S. trust (other than a granter grantor trust) and not the beneficiaries of the trusttrust Foreign person. If I am a foreign person, I do not use a Form W-9. Instead, use the appropriate Form W-8 or Form 8233 (see Pub 515, Withholding of Tax on Nonresident Aliens and Foreign Entities).

Appears in 1 contract

Samples: Account Agreement

Draft better contracts in just 5 minutes Get the weekly Law Insider newsletter packed with expert videos, webinars, ebooks, and more!