Section 1446 Withholding Calculator
Calculate the required withholding tax on effectively connected taxable income allocated to foreign partners.
Partner 1
Total Required Withholding
$0.00
Required Forms
- Form 8813 — Quarterly withholding payment voucher (due April 15, June 15, September 15, December 15)
- Form 8804 — Annual return for partnership withholding tax (Section 1446)
- Form 8805 — Foreign partner's information statement (one per foreign partner)
What is Section 1446 Withholding?
Section 1446 of the Internal Revenue Code requires partnerships that have effectively connected taxable income (ECTI) to withhold tax on the share of that income allocable to their foreign partners. This ensures the IRS collects tax on income earned by foreign persons through U.S. partnerships, even before the income is distributed.
When is Withholding Required?
Withholding is required whenever a partnership has ECTI that is allocable to one or more foreign partners. This applies regardless of the type of income — whether business income, rental income, or other income effectively connected with a U.S. trade or business.
Important: The partnership must withhold whether or not it actually distributes cash to its partners.
Can Withholding Be Reduced?
Yes. A foreign partner can submit Form 8804-C (Certificate of Partner-Level Items to Reduce Section 1446 Withholding) to the partnership. This form allows the partner to certify deductions and losses that reduce their allocable share of ECTI, which in turn reduces the required withholding amount.
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