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six_irs_section_1446f_tradingsymbol by Six Group

Dataset Name: six_irs_section_1446f_tradingsymbol

Group: government
Vendor: Six Group
Data Starts at: 2022-06-05 00:00:00
Symbol Set: tradingsymbol
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. (underlying field is nc_publish_date_actual)
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
ISIN string ISIN Country / ISIN Code - Structure of the code in accordance with ISO standard 6166: Nine digit alpha-numerical code assigned by the national numbering agency followed by one check digit.
Reportability string
PTP_Classification string
PTP_Applicability string

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