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PTP Tax Exemption

PTP TAX EXEMPTION

IRS Section 1446(f) Rule: Exemption

The IRS recently issued regulations on the withholding on transfers of interests in PTPs and on distributions made with respect to PTP interests, effective January 1, 2023. These regulations would require a 10% withholding on gains from the sale of PTP interests. 1446(f) rule is applicable to Publicly Traded Partnerships (PTPs) and may impact international investors in the following exchange-traded products (ETPs) registered under the Securities Act of 1933: CORN, WEAT, SOYB, CANE, TAGS.

  • ALL FUNDS LISTED ABOVE HAVE MET THE REQUIREMENTS AND ARE EXEMPT FROM IRS Section 1446(f) RULE.
  • An exception under this rule applies if a PTP is to certify that it is not engaged in a U.S. trade or business.
  • In order to make this certification, the PTP must state on a qualified notice that it is not engaged in a trade or business in the United States.
  • Teucrium intends to post a quarterly qualified notice to the website indicating that it has met the requirements for this exception.
  • This information may be used by foreign partners to indicate that the sale of their partnership interest should not be subject to the 10% withholding.

Click Here to download your Quarterly Notice for IRS Section 1446(f)

Please Contact Us if you have any questions.

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