Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-memo-section-1446-withholding.docx
tax-memo-section-1446-withholding.docx
Parties
Harkness LLP
Solara Digital Infrastructure LP
Solara Consolidated Master Fund LP
Consolidated Master Fund LP
Structure Solara Digital Infrastructure LP
Solara Digital Infrastructure GP LLC
Fund IV LP
Solara Offshore GP Ltd
Dates
March 17, 2014
March 31, 2025
September 15, 2025
October 1, 2025
October 15, 2025
November 1, 2025
December 1, 2025
June 16, 2025
Amounts
$880
$380
$500
€475
$513
1.08 EUR
€200
€275
$14.7
$4.2
Obligations
Overview of IRC § 1446(a) Section 1446(a) of the Code provides that, if a partnership has effectively connected taxable income for any taxable year, and if any portion of such income is allocable under IRC § 704 to a partner who is a foreign person, the partnership shall pay a withholding tax under § 1446(a) on behalf of such foreign partner
1446-1(c), the partnership must determine the amount of ECTI allocable to each foreign partner and withhold the applicable percentage of such amount
For the partnership to have an ECTI-based withholding obligation, there must be taxable income or gain that is allocable to a foreign partner