Administrative Adjustments Requests

ID: CCA_2009032414543037 Number: 200917038
Release Date: 4/24/2009
Office: ---
UILC: 6227.00-00
From: ---
Sent: Tuesday, March 24, 2009 2:54:33 PM
To: ---
Cc: ---
Subject: RE:
1. Have withholding returns filed now. That should end the matter. An AAR would only relate to a previously filed return so AAR procedures would not apply to an unfiled withholding tax return.
2. If the partnership files a withholding tax return and pays withholding tax, that would automatically be a deemed distribution of the paid tax to the foreign entity. There should be no need for any further filing.
But the partnership should reflect a reduced capital account going forward for the foreign partner in the amount of the distribution.