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1446-5(e)(3) and the LTP consents, the LTP has to pay the withholding tax on its ECTI allocated to the UTP's foreign partners. California had required a real estate withholding tax to be completed with the sale, and now the client was due a sizeable refund--except the withholding was credited to the trust, not to her. But employers have not been required to (1) track all "supplemental" wages--as that term is defined by the proposed regulations--and, more important, (2) test the cumulative "supplemental" wages paid year-to-date on a continuing basis against a fixed-dollar threshold for purposes of applying the withholding tax rules. |
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