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Tax Court Holds Fund Engaged in U.S. Business via Investment Manager, Owes Withholding Tax
December 6, 2023ArticleTax Court Holds Fund Engaged in U.S. Business via Investment Manager, Owes Withholding Tax
December 6, 2023The Tax Court in a November 15 decision held that an investment fund partnership was engaged in a U.S. trade or business through the activities of its investment manager that acted as its agent, and consequently the partnership was liable for withholding taxes for the portion of its effectively connected income allocable to its foreign partners (YA Global Investments LP V. Commissioner, 161 T.C. No. 11).
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