Corporations are often today converted into “disregarded entities” for tax purposes, such as avoiding “double taxation”. A disregarded entity is a business that is not separated from the owner for tax purposes.
Under Internal Revenue Code “IRC” Section 1446, a partnership of this sort may be made up of any kind of foreign corporation, international organization, non-resident individual or foreign estate or trust. Any partnership that falls under the definition of 1446 must pay the required withheld taxes mandated by the IRS.