QUALIFIED NOTICE
We are required to provide qualified notice to brokers and nominees that hold USD Partners LP units on behalf of non-U.S. investors under Treasury Regulation Sections 1.1446-4(b) and (d) and 1.1446(f)-4(c)(2)(iii). Brokers and nominees should treat one hundred percent (100.0%) of USD Partners LP’s distributions to non-U.S. investors as being attributable to income that is effectively connected with a United States trade or business. In addition, brokers and nominees should treat one hundred percent (100%) of the distribution as being in excess of cumulative net income for purposes of determining the amount to withhold. Accordingly, USD Partners LP’s distributions to non-U.S. investors are subject to federal income tax withholding at a rate equal to the highest applicable effective tax rate plus ten percent (10%). Nominees, and not USD Partners LP, are treated as the withholding agents responsible for withholding on the distributions received by them on behalf of non-U.S. investors.
Separately, for the purposes of withholding on sales transactions by non-U.S. investors under Treasury Regulation Section 1.1446(f)-4(a)(2), brokers should treat one hundred percent (100%) of the proceeds attributable to the sale of Partnership units as being attributable to a U.S. trade or business.
For specific Qualified Notices, click here.