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View Diary: Romney Parks Millions in Offshore Tax Havens UPDATE 2 (309 comments)

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    flitedocnm

    A foreign partnership is a foreign partnership is a foreign partnership.

    There is a difference between "taxed as a partnership for U.S. tax purposes" and a "U.S. partnership."  For example, all U.S. partnerships (i.e., those organized in a state or D.C.) must file a U.S. tax return.  A foreign partnership--even one that makes an election to be taxed as a partnership for U.S. tax purposes--files only if it has a U.S. trade or business, or income effectively connected with the United States.  Withholding rules are also different.

    "Well, I'm sure I'd feel much worse if I weren't under such heavy sedation..."--David St. Hubbins

    by Old Left Good Left on Thu Jan 19, 2012 at 08:15:03 AM PST

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