Partnerships/Multi-Member LLCs

A US partnership or multi-member LLC taxed as a partnership for US income tax purposes reports its worldwide income to the IRS on Form 1065 “U.S. Return of Partnership Income.” Partnerships and multi-member LLCs taxed as partnerships are subject to one level of tax. Income, gain, deduction and loss of the partnership or multi-member LLC from whatever source are passed through to the owners according to the agreement among the owners. The owners reflect the income, gain, deduction and loss (subject to certain limitations) on their own tax returns according to the rules that apply to each owner — for example, if the owner is a US Person for US tax purposes, he would include on his own tax return, subject to exclusion, exemptions and deductions, his share of the partnership or LLC’s worldwide income. Later distributions of previously taxed earnings, are generally not taxable to the owners.

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