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The video discusses the new Section 1446(f) concerning withholding taxes on sales of partnerships engaged in U.S. business. It begins by reviewing existing rules regarding ongoing earnings of partnerships versus their sales. For instance, in a U.S. partnership with 50% U.S. and 50% foreign ownership, the foreign partner is deemed to be engaged in a U.S. business under Section 875(1) due to the partnership's operations. Regardless of whether the partnership is a U.S. or foreign entity, the key factor is its engagement in a U.S. business. According to Section 1446(a), the partnership must withhold on income effectively connected to the U.S. business that is allocable to the foreign partner, and it files forms 8804, 8805, and 8813.
