Other rules
(4) Other rules(i) Exclusion of items allocated to U.S. partners. Except as provided in 1.1446-5(e), in computing partnership ECTI, the partnership shall not take into account any item of income, gain, loss, or deduction to the extent allocable to any partner that is not a foreign partner, as that term is defined in 1.1446-1(c). (ii) Partnership credits. See 1.1446-3(a) providing that the 1446 tax is computed without regard to a partner's distributive share of the partnership's tax credits. (iii) Special rule for qualified holders. With respect to a foreign partner that is a withholding qualified holder (as defined in 1.1445-1(g)(11)), the foreign partner's allocable share of partnership ECTI does not include gain or loss that is not taken into account under 1.897(l)-1(b) and that is not otherwise treated as effectively connected with a trade or business in the United States. The partnership must have received from the partner a valid certificate of non-foreign status (including a Form W-8EXP) described in 1.1445-2(b)(2)(i) or 1.1445-5(b)(3)(ii). See 1.1446-1(c)(2)(ii)(G) and (H) regarding documentation of withholding qualified holders. (5) Examples. The following examples illustrate the application of this section. In considering the examples, disregard the potential application of 1.1446-3(b)(2)(v)(F) (relating to the de minimis exception to paying 1446 tax). The examples are as follows: