On 1st January 2023, the IRS’ new Internal Revenue Code Section 1446(f) will become effective. It will impact proceeds from sales of Publicly Traded Partnerships (PTPs) held by non-U.S. tax residents. All sales will become subject to a 10% withholding tax.
What does this mean?
If you sell a position worth $5,000, even if no profit is generated, there will be a $500 withholding tax. As a result, you’ll receive $4,500.
What will Trading 212 do?
Due to the tax obligations of holding and maintaining these instruments, we will discontinue offering Publicly Traded Partnerships.
How will this impact me?
If you do not hold an open position (CFD, Invest or ISA) in a PTP instrument, a new one cannot be opened.
If you have an open position with a PTP instrument(s), you have until market close on December 29th to close or modify. We’ll instruct a market order on December 30th to liquidate any remaining holdings. This will guarantee that no 10% withholding tax is applied.
The official IRS statement can be found 👉 here.
Below, you may find the full list of affected instruments 👇. It is subject to change at any time.
(UPDATE: 16.12.2022)
A Qualified Notice (QN)* applies for BEP and BIP** making them exempt from the 10% wihholding tax. These instruments won't be impacted by the December 30th mandatory closure and discontinuation, which is why they have been marked with an ❌.
All the other above-listed changes are still valid for the rest of the instruments in the table.
| Instrument Name | Ticker | ISIN |
| Brookfield Infrastructure Partners ❌ | BIP | BMG162521014 |
| Brookfield Renewable Partners ❌ | BEP | BMG162581083 |
| Lazard | LAZ | BMG540501027 |
| Alliance Resource Partners | ARLP | US01877R1086 |
| AllianceBernstein | AB | US01881G1067 |
| Black Stone Minerals | BSM | US09225M1018 |
| CVR Partners | UAN | US1266332055 |
| DCP Midstream | DCP | US23311P1003 |
| Energy Transfer | ET | US29273V1008 |
| Invesco DB US Dollar Index Bullish Fund | UUP | US46141D2036 |
| NGL Energy Partners | NGL | US62913M1071 |
| Plains All American Pipeline | PAA | US7265031051 |
| ProShares Ultra VIX Short-Term Futures | UVXY | US74347Y8396 |
| ProShares Ultra Bloomberg Natural Gas | BOIL | US74347Y8701 |
| United States Oil Fund | USO | US91232N2071 |
| United States Natural Gas Fund LP | UNG | US9123183009 |
| ProShares Short VIX Short-Term Futures | SVXY | US74347W1302 |
| Holly Energy Partners | HEP | US4357631070 |
| MPLX | MPLX | US55336V1008 |
| Enterprise Products Partners | EPD | US2937921078 |
| Cedar Fair | FUN | US1501851067 |
| Magellan Midstream Partners | MMP | US5590801065 |
| Western Midstream Partners | WES | US9586691035 |
| Suburban Propane Partners | SPH | US8644821048 |
| NuStar Energy | NS | US67058H1023 |
| Cheniere Energy Partners | CQP | US16411Q1013 |
| Icahn Enterprises | IEP | US4511001012 |
| RTW Venture Fund | RTW |
GG00BKTRRM22
|
| Gyrodyne | GYRO | US4038291047 |
| 1847 Holdings | EFSH | US28252B8046 |
| Global Indemnity | GBLI | US37959R1032 |
| USA Compression Partners | USAC | US90290N1090 |
| USD Partners | USDP | US9033181036 |
| Global Partners | GLP | US37946R1095 |
| Evolve Transition Infrastructure | SNMP | US30053M1045 |
| Sunoco | SUN | US86765K1097 |
| Westlake Chemical Partners | WLKP | US9604171036 |
| Crestwood Equity Partners | CEQP | US2263442087 |
| Belpointe Prep | OZ | US0806941029 |
| Calumet Specialty Products Partners | CLMT | US1314761032 |
| Delek Logistics Partners | DKL | US24664T1034 |
| Summit Midstream Partners | SMLP | US8661424098 |
| Dorchester Minerals | DMLP | US25820R1059 |
*As per IRC Sec. 1446(f), PTPs with active Qualified Notices (QN) are not subject to the 10% withholding tax. The PTP is required to reissue Qualified Notices every 92 days. Information about these notices can be obtained from the PTP website.
**If the QNs are not renewed, we will notify existing shareholders about the BIP/BEP liquidation requirement.