IRS NOTICE REFERENCE
Understanding Your CP282 Notice
You received this notice because you indicated on your Form 1065, U.S. Return of Partnership Income, or Form1065-B, U.S. Return of Income for Electing Large Partnerships, that you have foreign partners. Generally, when a…
General information only. Not legal or tax advice.
Notice details
- Notice code
- CP282
- Category
- Filing and non-filer
- Severity tier
- Tier 2 — Action or response expected. The IRS has taken or proposed an action and expects a response or payment.
- Governing law
- §6651; §6012 (Internal Revenue Code sections)
- Source
- IRS.gov — Understanding Your IRS Notice
What this notice is
You received this notice because you indicated on your Form 1065, U.S. Return of Partnership Income, or Form1065-B, U.S. Return of Income for Electing Large Partnerships, that you have foreign partners. Generally, when a foreign person engages in a trade or business in the United States, all income from sources in the United States connected with the conduct of that trade or business is considered to be Effectively Connected Taxable Income (ECTI) . A partnership (foreign or domestic) that has income effectively connected with a U.S. trade or business (or income treated as effectively connected) must pay a withholding tax on the ECTI that it allocates to its foreign partners (Section 1446 of the Internal Revenue Code). The partnership, or a withholding agent for the partnership, must pay the withholding tax. A partnership that must pay the withholding tax but fails to do so may be liable for the payment of the tax plus any penalties and interest.
Source: IRS.gov. Reproduced for reference. General information — not legal or tax advice.
Governing IRS procedure (Internal Revenue Manual)
The IRS’s own internal procedures for handling this notice type are documented in the Internal Revenue Manual:
- IRM 5.1.11 — 5.1.11 Delinquent Return Investigations
- IRM 5.18.1 — 5.18.1 Automated Substitute for Return (ASFR) Program
- IRM 4.12.1 — 4.12.1 Nonfiled Returns
Reference to published IRS procedure. General information — not legal or tax advice.
Official IRS reference
Read the official notice page on IRS.gov: https://www.irs.gov/individuals/understanding-your-cp282-notice
Related tools
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