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Form 8805 for Eugene Oregon: What You Should Know
IRS Issues Guidance on Tax ability of Inherently Disposition Acquisitions by Foreign Partners Oct 27, 2025 — Effective for income tax years beginning after December 31, 2021, the transferor of an inherent disposition acquires U.S. source income attributable to such disposed investment for purposes of determining U.S. tax on that income for the tax year, and the transferee of such disposed investment may use that income as a basis for determining U.S. source tax without regard to the limitation on the transferor's allocable share of that income. IRS Issues Forms 1099-B and 1099-MISC to Non-U.S. Entities for Partner Income Apr 21, 2025 — Forms 1099-B and 1099-MISC are used by a non-U.S. business partner (PEP) to report to a U.S. business partner (PBA) the income to its PEP of income generated from foreign sources by those PEP partners engaged in various activities, each of which occurs under a limited partnership. The term “foreign sources income” in section 513(a) is generally applied to income derived from sources other than the United States. IRS Issues Form 1099-MISC to Non-U.S. Entities, Reclassifies Foreign Partner's U.S. Source Income as Inherently Disposition Acquisitions of U.S. Property Jan 27, 2025 — As part of a recent guidance change, an IRS notice issued on January 23, 2015, reclassifies income of a tax year of a foreign partner under section 469 for purposes of determining the value of the partnership's total adjusted basis of property owned by the partnership at the end of such taxable year. The Partnership Tax Reform Act of 2015: An Update to the Foreign Tax Credit and Partnership Asset Test Aug 23, 2015 The Partnership Tax Reform Act of 2025 (Project) requires non-U.S. entities to report their partnership income, expenses, and losses. Non-U.S. entities must complete a U.S. partner federal income tax return and pay a 10% tax on U.S. partnership tax avoidance. IRS Issues Final Regulations: Form 1098-D and Form 1098-NR for Nonresident Alien Qualified Domestic Partnerships, and Modifies Procedures for Partnership Property Received as Compensation at Yield-Sharing or Profit Sharing Transactions.
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