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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

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