TaxGuided
United States IRC sections

Statute section

IRC section 1446

Withholding of tax on foreign partners' share of effectively connected income

Country

United States

Section

1446

Updated

2026-05-04

Operative text

Section 1446 requires partnerships with effectively connected taxable income allocable to foreign partners to pay withholding tax under rules prescribed by the Secretary. It also includes the modern withholding framework for certain dispositions of partnership interests under subsection (f).

Cross-references

26 U.S.C. 86426 U.S.C. 70426 U.S.C. 1446(f)

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