Understanding Your CP282 Notice


What this notice is about

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:

If you determine you're not liable for withholding:

  • Write ”not liable” on the notice
  • Don’t write that you have no taxable income
  • Send the notice to the address at the top of the notice

If you already filed the appropriate forms:

  • Write on the notice the names of the forms you already filed
  • Send the notice to the address at the top of the notice

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