Ask Tax Question

An irrevocable foreign trust (with US beneficiaries) owns 85% of a domestic US LLC. The LLC received dividends from a domestic US corporation. All the income from foreign trust is distributed to the US beneficiaries, and they ultimately pay tax on all the trust's income (incl. dividends received).

If all US beneficiaries of the foreign trust will pay tax on the income distributed by the trust, does the LLC need to withhold tax on the income allocated to the foreign trust under Section 1446; even though, the LLC's income will be paid by the US beneficiaries?
If this withholding is applicable, then how will the US beneficiaries claim the credit for the withholding taxes paid if the irrevocable foreign trust doesn't prepare a US tax return?
Withholding Requirement Estate & Trust

Meet Leading Tax Advisors

User Photo Kathryn Morgan

Bossier City, Louisiana, USA

Enrolled Agent, Master Tax Advisor

User Photo Peter J. Scalise

New York, New York, USA

Federal Tax Credits & Incentives Practice Leader

User Photo John Stancil

Lakeland, Florida, USA

Tax Advisor/CEO

User Photo John Dundon, II EA

Denver, Colorado, USA

Tax Director

User Photo Steven Potts JD EA IAR

Fullerton, California, USA


User Photo Devon McCarthy FCCA, EA

Sanford, Florida, USA


User Photo Caran Ebert, CPA

Topanga, California, USA

Tax Advisor

User Photo Lisa Nason CPA, MST

Greenville, South Carolina, USA

Managing Shareholder

User Photo Randy Tarpey

Tyrone , Pennsylvania, USA



Santa Clara, California, USA

Tax Principal - President

User Photo Bill Robinson, CPA

Chattanooga, Tennessee, USA


User Photo Hugo Van Zyl

Stellenbosch, South Africa

Exchange Control & Master Tax Practitioner (SA)

User Photo Douglas Stransky

Boston, Massachusetts, USA

Tax Partner, International Tax

User Photo Larry Stolberg, CPA, CA

Toronto Mississauga Oakville Burlington Hamilton, Canada

Tax Specialist

User Photo Dr. Daniel Erasmus

West Palm Beach, Florida, USA

Managing Partner/EMEA

View/Select our Current List of Tax Topics

# A B C D E F G H I J K L M N O P Q R S T U V W X Y Z

Previous PageNext Page

Contact Us Today