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Please note that as a foreign account holder, you may be subject to new/increased U.S. withholding tax by the upcoming section 1446(f) regulation effective as of 01/01/2023.
Section 1446(f) of the U.S. Internal Revenue Code imposes new withholding and reporting requirements on sales of partnership interest. Generally, the securities affected are classified as partnerships for U.S. tax withholding purposes. Such securities include Master Limited Partnerships, Publicly Traded Partnerships, and Exchange Traded Funds.
Any foreign accounts holding securities that are in scope for section 1446(f) will be subject to additional withholding requirements on and after 01/01/2023.
Current section 1446 regulations already extend to include withholding on partnership distributions. Starting 01/01/2023, additional requirements include a new 10% withholding tax on distributions and 10% withholding tax on proceeds from partnership securities.