Table of Contents
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Final regulations were issued under section 1.1446-6. These final regulations address special rules to reduce a partnership's section 1446 tax with respect to a foreign partner's allocable share of effectively connected taxable income (ECTI).
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Effective July 29, 2008, Form 8804-C, Certificate of Partner-Level Items to Reduce Section 1446 Withholding, is the sole method for foreign partners to certify partner-level items. See Certification of Deductions and Losses on page 3 for details.
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The automatic extension period granted by the filing of Form 7004, Application for Automatic Extension of Time To File Certain Business Income Tax, Information, and Other Returns, has been reduced from 6 months to 5 months. See Form 7004 for additional information.
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