Dataset Name: six_irs_section_1446f
Group: government
Vendor: Six Group
Data Starts at: 2022-06-05 00:00:00
Symbol Set: Equities
Asset Class: Equity,ADRs,ETFs,Fixed Income,Options,FX,Futures
Data Update Time(s): EOD daily
Data Update Frequency: day
Six Group Tax IRS Section 1446(f) for partnerships
On 30 November 2020, the Department of the Treasury and the Internal Revenue Service ("IRS") published final regulations under Section 1446(f) relating to withholding obligations for certain dispositions by foreign partners of interests in partnerships.
The regulation will enter into force on 1 January 2023.
According to this new regulation, brokers and/or withholding agents, as well as qualified intermediaries ("QIs"), are obliged to withhold a tax of 10% on the disposition on behalf of a foreign partner of interest in a publicly traded partnership ("PTP").
In principle, the sale of interests in PTPs by non-US persons is taxed at 10% of the realized amount. This applies to all PTPs that are engaged in a US trade or business, meaning that are commercially active in the US and thus generating effectively connected income ("ECI").
Data Contained in this Dataset
| Column | Type | Description |
|---|---|---|
| _seq | uint | Internal sequence number used to keep data rows in order |
| timestamp | string | Timestamp of the Data - America/New York Time. |
| muts | uint64 | Microseconds Unix Timestamp. An integer representation of a timestamp with microsecond precision that can be compared directly to other timestamps. |
| symbol | string | Trading Symbol or Ticker |
| Valor | int | Valor ID |
| Instrument_ShortName | string | Short name for instrument |
| Institution_Name | string | Name of institution |
| Instrument_Type | string | Type of instrument |
| Instrument_Type_desc | string | Description of type of instrument |
| Instrument_Status | string | Status of instrument |
| Reportability | string | |
| PTP_Classification | string | |
| PTP_Applicability | string |
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