artnership formed in the US; has two partners one partner is a resident the other partner is a nonresident US partner. The partnership will be fifty – fifty ownership but the foreign US partner share losses and gains of the partnership is 0% for now as the resident partner performs all the services.
I think I would need to obtain Form 6166 for his LLC. Taxpayer said the Italian company is asking for a double tax exemption certificate. Is there such a thing as a double tax exemption certificate? Is form 6166 the only thing a US tax payer can use in this type of situation?
Partnership has two partners, one is a nonresident foreign partner who lives in Greece the other is a US citizen. They’re sources of income are capital gains and fee’s received for the management of clients’ portfolios. Both partners are actively involved in the business so I would say it’s effectively connected income to the non-resident alien partner.
The exchange rate used is dependent on the depreciable base for the property. As you may note per IRS Publication 527, the lower of the fair market value (FMV) or cost basis is used to start depreciating the property.
We’ve reviewed several portions of the tax code including the Foreign Investment in Real Property Tax Act (FIRPTA) again. It is our understanding that your client’s non-resident alien Italian mother would in fact be subject to withholding and taxes on the sale even though this is a personal residence.