Logistics Partners, LP (the “Partnership”). If you are not a non-U.S. investor and you do not act as custodian for a non-U.S. investor, you may ignore this notice.
Section I – Distribution Withholding:
This notice is intended to serve as qualified notice under Treasury Regulation Section 1.1446-4(b). Brokers and nominees should treat one hundred percent (100%) of the Partnership’s distributions to non-U.S. investors as being attributable to income that is effectively connected with a United States trade or business. Accordingly, the Partnership’s distributions to non-U.S. investors are subject to federal income tax withholding at the highest applicable effective tax rate.
Section II – Withholding on Distributions in Excess of Cumulative Net Income:
The Partnership does not calculate cumulative net income for purposes of Treasury Regulation Section 1.1446(f)-4(c)(2)(iii). Consequently, 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.
Section III – Withholding on Transfers of Units:
For the purposes of withholding on sales transactions 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.
Any non-U.S. investors subject to withholding that would like a quarterly estimated K-1, please contact investor relations at 615-767-4344.
A copy of this notice will also be available on the Partnership’s website (currently available at www.deleklogistics.com).