Understanding Your CP282 Notice

You received this notice because you indicated on your Form 1065, U.S. Return of Partnership Income, or Form1065-B, U.S. Return of Income for Electing Large Partnerships, that you have foreign partners.

Generally, when a foreign person engages in a trade or business in the United States, all income from sources in the United States connected with the conduct of that trade or business is considered to be Effectively Connected Taxable Income (ECTI). A partnership (foreign or domestic) that has income effectively connected with a U.S. trade or business (or income treated as effectively connected) must pay a withholding tax on the ECTI that it allocates to its foreign partners (Section 1446 of the Internal Revenue Code). The partnership, or a withholding agent for the partnership, must pay the withholding tax. A partnership that must pay the withholding tax but fails to do so may be liable for the payment of the tax plus any penalties and interest.

What you need to do if you determine you are liable for withholding:

Printable samples of this notice (PDF)

Need Help?

  • You can authorize someone to contact the IRS on your behalf.
  • See if you qualify for help from a Low Income Taxpayer Clinic.
  • If you can’t find what you need online, you can call the IRS at the 800, 866, or 888 number listed on the notice.