| Which Partnerships are required to file Form 8804 and Form 8805?
Per the IRS, "Every partnership (other than a publicly traded partnership) that has effectively connected gross income allocable to a foreign partner must file a Form 8804, regardless of whether it had ECTI allocable to a foreign partner."
The IRS has also stated that the "partnership must also file a Form 8805 for each partner on whose behalf it paid section 1446 tax, regardless of whether the partnership made any distributions during its tax year."
The partnership, or person it designates, must file these forms even if the partnership has no withholding tax liability under section 1446.
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