A foreign partner (member) in a LLC



If a LLC operated as partnership here in US has a couple of partners
(members) who are citizens and residents of Guam, would they be deemed
foreign partners and hence the US business as part of Federal Income
tax filing of Form 1065, would be required to file form 8804, 8805 and

In this particular case, there is a net taxable loss.

Would the US business be subject to paying withholding tax on
"effectively connected taxable income allocable to foreign partners?"

Thanks in advance.


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