# Prop. Treas. Reg. § 1.1446-3: Time and manner of calculating and paying over the 1446 tax.

Proposed regulation, not in force. REG-115420-18, 86 FR 19585, published 2021-04-14 <https://www.federalregister.gov/documents/2021/04/14/2021-06143/requirements-for-certain-foreign-persons-and-certain-foreign-owned-partnerships-investing-in>. Interprets 26 U.S.C. § 1446.

Par. 8. Section 1.1446-3 is amended by revising paragraph (b)(2)(i)(B)( 1 ) introductory text to read as follows:

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(b) * * *

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(i) * * *

(B) * * *

( 1 ) To the extent applicable, in computing the 1446 tax due with respect to a foreign partner, a partnership may consider a certificate received from such partner under § 1.1446-6(c)(1)(i), (ii) or (iv) and the amount of state and local taxes permitted to be considered under § 1.1446-6(c)(1)(iii). For this purpose, a partnership shall first consider under § 1.1446-6(c)(1)(iv) the partner's permitted deferral amounts and then annualize the partner's allocable share of the partnership's items of effectively connected income, gain, deduction, and loss before—

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