Form 1042-S reports U.S.-source income paid to foreign persons and the tax withheld on it, and you fill it out by entering the payee’s identity, the income code, the gross amount, the chapter 3 or chapter 4 withholding rate, the tax withheld, and any treaty exemption claimed. Withholding agents must file one Form 1042-S for each recipient and each income type, then report the totals on the related Form 1042 annual return by March 15 of the year after payment.
The problem the form solves is tracking U.S. tax on Foreign Derived Annual or Periodical (FDAP) income paid to nonresidents, and missing a box, an income code, or a treaty article can trigger penalties, blocked treaty refunds, and IRS notices for both the agent and the foreign payee. The IRS reports that more than 5.5 million Forms 1042-S are filed each year, with billions in withheld tax flowing through the system, so even small filing errors scale fast.
Here is what you will learn in this guide:
- 📄 How to fill in every box on the 2025 Form 1042-S, line by line, with the right income, exemption, and chapter codes
- 🌍 How treaty claims under Publication 515 and Form W-8BEN/W-8BEN-E flow into boxes 16a–17c
- 💼 Three real scenarios: a Canadian consultant, a German dividend shareholder, and an Indian graduate student on a scholarship
- ⚠️ The seven most common mistakes that trigger IRS penalties under IRC §6721 and §6722
- 🖥️ How to e-file through the new IRIS platform and the FIRE system under the 10-return threshold
What Form 1042-S Is and Who Must File It
Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, is the information return that a withholding agent uses to report U.S.-source FDAP income paid to a foreign person during the calendar year. The form covers payments under both Chapter 3 (nonresident alien withholding under IRC §1441) and Chapter 4 (FATCA withholding under IRC §1471). It pairs with Form 1042, the summary return that totals every 1042-S a payer issues that year.
A withholding agent is any U.S. or foreign person who has control, receipt, custody, disposal, or payment of U.S.-source FDAP income to a foreign person. The plain-English meaning is that if you cut a check, run a payroll, or transfer property to a foreign payee, you are likely the agent. The consequence of ignoring this duty is direct personal liability for the unwithheld tax under Treas. Reg. §1.1461-1, plus interest and penalties.
A common misconception is that only banks and brokers file Form 1042-S. In reality, universities paying scholarships, law firms paying foreign experts, software companies paying royalties, and even small businesses paying a single foreign contractor must file. A real example: Maria Lopez, who runs a Texas marketing agency, hires a freelance designer in Spain for $4,000 and assumes a Form 1099 is enough. She must instead issue Form 1042-S because the payee is a foreign person, and the consequence of using the wrong form is a separate penalty for each return.
Income Types That Trigger a Form 1042-S
The form captures FDAP income, which includes interest, dividends, rents, royalties, scholarships, fellowships, prizes, gambling winnings, pensions, and compensation for personal services. It also captures gross proceeds, certain real estate gains under FIRPTA, and partnership ECI allocations under IRC §1446. Each income stream gets its own income code in box 1.
The reason each type gets a code is that treaty rates and exemption rules differ. The consequence of using the wrong code is that the IRS may deny a treaty claim or assess underwithholding. Akira Tanaka, a Japanese pension recipient, lost his treaty rate for a year because the payer used income code 14 (real property income) instead of code 15 (pensions and annuities).
Who Is a Foreign Person for 1042-S Purposes
A foreign person includes a nonresident alien individual, a foreign corporation, a foreign partnership, a foreign trust, a foreign estate, and certain foreign branches. The status comes from a valid Form W-8 series on file, or from the presumption rules in Treas. Reg. §1.1441-1(b)(3). The plain meaning is that without a W-8, you treat the payee as foreign or as undocumented under presumption rules.
The consequence of relying on a stale or invalid W-8 is full statutory withholding at 30 percent and loss of any treaty rate. A common misconception is that a foreign passport alone proves nonresident status; in fact, the substantial presence test can convert a foreign national into a U.S. tax resident, who then receives a Form W-2 or 1099, not a 1042-S.
When and How to File Form 1042-S
The filing deadline is March 15 of the year following the calendar year of payment, the same date as the related Form 1042. You can request an automatic 30-day extension by filing Form 8809 before the original due date. Recipient copies (Copy B, C, and D) must reach the foreign payee by March 15 as well, though Copy A goes to the IRS.
Under Treasury Decision 9972, any filer with 10 or more information returns of any type combined must e-file. The threshold counts Forms W-2, 1099, 1095, and 1042-S together, so a small business with eight 1099s and three 1042-S forms must e-file all of them. The consequence of paper filing when you are required to e-file is a per-return penalty under IRC §6721.
A common misconception is that the FIRE system still handles 1042-S. As of tax year 2025, filers can use either the legacy FIRE system or the newer Information Returns Intake System (IRIS). Daniel Okafor, a payroll director at a Boston biotech, switched to IRIS in 2025 to handle 40 foreign researchers and cut his filing time in half by uploading a single CSV.
Where to Send Paper Forms
If you qualify for paper filing because you have fewer than 10 returns total, mail Copy A with Form 1042-T (the transmittal) to the Ogden Service Center in Utah. The address appears in the Instructions for Form 1042-S. Send recipient copies to the foreign address on file, or to the U.S. address if the payee is temporarily in the United States.
The reason the IRS uses Ogden is that it centralizes international information returns. The consequence of sending paper to the wrong service center is a delayed posting that can hold up the payee’s refund claim. A common misconception is that you can fold or staple Copy A; the IRS scans these forms, so creased or stapled forms get rejected.
Penalties for Late or Wrong Filing
The penalty under IRC §6721 for a return filed late or with errors is tiered: $60 if filed within 30 days, $130 if filed by August 1, and $340 if filed after that or not at all, indexed for inflation. Intentional disregard pushes the penalty to $680 per return with no cap. A parallel penalty under IRC §6722 applies to the recipient copy.
The plain meaning is that one wrong 1042-S can cost up to $1,360 between the IRS copy and the recipient copy. The consequence at scale is severe: a university issuing 500 scholarship 1042-S forms with a wrong income code could face a six-figure exposure. Sofia Ramirez, a CFO at a small fund administrator, paid $42,000 in 1042-S penalties in 2024 because her team filed all forms with a blank box 13b country code.
Step-by-Step: Filling Out Every Box on Form 1042-S
The 2025 Form 1042-S has 23 numbered boxes plus identifying boxes for the unique form identifier and amendment indicator at the top. Each box has a precise purpose, and the official instructions list exact codes for income, exemption, recipient, and limitation on benefits. Work through the boxes in order, using the W-8 on file as your source of truth.
Top of Form: Unique Form Identifier and Amended Indicator
At the very top, enter a 10-digit Unique Form Identifier (UFI). The UFI must be numeric, must not start with zero, and must be unique within the calendar year for that withholding agent. The reason the IRS requires a UFI is that it ties amendments back to the original return.
The consequence of reusing a UFI is that the amended return overwrites or duplicates a different recipient’s filing. Check the AMENDED box only when correcting a previously filed Form 1042-S, and check Pro-Rata Basis Reporting only if a qualified intermediary elects pooled reporting. Liam Walsh, an Irish musician, had his treaty refund delayed nine months because his agent reused UFI “1000000001” for two amendments.
Box 1: Income Code
Box 1 is a two-digit code that defines the type of income. Income code 06 is dividends paid by U.S. corporations, code 12 is other royalties, code 16 is scholarship or fellowship grants, code 17 is independent personal services, code 18 is dependent personal services, code 20 is studying and training payments, and code 50 covers other income. The full list appears in Appendix A of the instructions.
The plain-English meaning is that this code drives every other rate and exemption decision downstream. The consequence of choosing the wrong code is that the IRS systems may flag a treaty claim as inconsistent and deny it. A common misconception is that you can lump multiple income types on one form; you must issue a separate 1042-S for each income code, even if the same payee receives several.
Box 2: Gross Income
Enter the gross amount paid before any withholding. Round to whole dollars. Do not net the withholding out of this number.
The reason gross is required is that the IRS recomputes withholding to verify accuracy. The consequence of reporting net pay is that box 7a (federal tax withheld) will not reconcile, triggering an automated CP-2100 mismatch notice. Priya Shah, an Indian software engineer paid $10,000, sees gross income $10,000 in box 2 and tax withheld $3,000 in box 7a if no treaty applies.
Box 3: Chapter Indicator and Boxes 3a, 3b, 4a, 4b
Box 3 holds either “3” or “4” to indicate which chapter applies to the payment. Box 3a is the Chapter 3 exemption code (for example, 04 for treaty benefits), and box 3b is the Chapter 3 tax rate. Box 4a is the Chapter 4 exemption code, and box 4b is the Chapter 4 tax rate.
The plain meaning is that one chapter governs the withholding and the other is reported as zero or as exempt. The consequence of mismatched chapter codes is FATCA noncompliance and potential 30 percent withholding on top of the Chapter 3 amount. A common misconception is that Chapter 4 only matters for foreign banks; in fact, any payment to a non-participating FFI without proper documentation triggers FATCA.
Boxes 5–8: Withholding Allowance, Net Income, Tax Rate, Federal Tax Withheld
Box 5 is the withholding allowance, used only for scholarships and personal services. Box 6 is net income, used only when an allowance is claimed. Box 7a is the federal tax actually withheld, box 7b is reserved, and box 7c is for tax withheld by other agents.
The reason these boxes exist separately is that the IRS reconciles them against the Form 1042 deposits. The consequence of an arithmetic mismatch is an automatic notice and a possible deposit penalty under IRC §6656. Box 8 captures tax withheld by another agent, useful when a chain of intermediaries handled the payment.
Boxes 9–11: Overwithheld Tax, Total Withholding Credit, Tax Paid by Withholding Agent
Box 9 reports tax repaid to the recipient under the reimbursement or set-off procedures. Box 10 is the total withholding credit, which is the sum of 7a, 8, and 9 with the right signs. Box 11 reports tax paid by the withholding agent out of pocket when the agent grosses up the payment.
The plain meaning is that these boxes track who actually bore the tax. The consequence of leaving box 10 blank is the recipient cannot claim the credit on Form 1040-NR. Chen Wei, a Chinese investor, lost a $2,800 refund because his broker left box 10 empty on a corrected form.
Boxes 12a–12i: Withholding Agent Identification
Boxes 12a through 12i identify the withholding agent. Box 12a is the agent’s EIN, box 12b is the Chapter 3 status code, box 12c is the Chapter 4 status code, box 12d is the agent’s name, and 12e through 12i hold the address and GIIN for FATCA-registered agents.
The reason the IRS demands a Chapter 3 and Chapter 4 status code is that it identifies the agent’s role in the payment chain. The consequence of mismatched status codes is suspension of FATCA registration. A common misconception is that a U.S. corporation does not need a GIIN; if it is acting as a sponsoring entity, it does.
Boxes 13a–13l: Recipient Information
Box 13a is the recipient’s name, box 13b is the country code (use the two-letter ISO codes), box 13c is the address, box 13d is the recipient’s U.S. TIN (ITIN, SSN, or EIN), box 13e is the foreign tax identifying number, box 13f is the Chapter 3 status code, box 13g is the Chapter 4 status code, box 13h is the date of birth for individuals, box 13i is the GIIN, and 13j through 13l capture LOB code and account number where applicable.
The plain meaning is that this block must match the W-8 exactly. The consequence of a mismatched name or TIN is a backup withholding cascade and a frozen treaty claim. Olusegun Adebayo, a Nigerian researcher, had his treaty rate denied because box 13d showed an expired ITIN that he had not renewed under the PATH Act renewal rules.
Boxes 14–15: Primary Withholding Agent and Intermediary
Box 14a and 14b identify a primary withholding agent when a separate party assumed primary responsibility, common in QI arrangements. Box 15 captures information for an intermediary or flow-through entity that received the payment before it reached the ultimate recipient, including its name, country, TIN, GIIN, Chapter 3 status, and Chapter 4 status.
The reason the IRS tracks intermediaries is to enforce the QI/WP/WT Agreement. The consequence of leaving box 15 blank when an intermediary exists is that the chain breaks and the IRS may assess full 30 percent withholding to the U.S. payer.
Boxes 16a–17c: Payer and State Tax Information
Box 16a through 16e capture the payer when the payer differs from the withholding agent, plus the payer’s TIN, GIIN, and chapter statuses. Box 17a is state income tax withheld, box 17b is the payer’s state tax number, and box 17c is the two-letter state code.
The plain meaning is that some states (such as California and New York) impose their own nonresident withholding. The consequence of skipping the state boxes is a state-level penalty even when the federal return is perfect. A common misconception is that 1042-S handles only federal tax; states piggyback on these forms for nonresident reporting.
Treaty Benefits and Exemption Codes
Treaty benefits flow from a valid Form W-8BEN (individual) or Form W-8BEN-E (entity), with the treaty country, article, and rate stated by the payee. The agent then enters Chapter 3 exemption code 04 in box 3a, the reduced rate in box 3b, and the LOB code in box 13j for entities. The treaty article appears in box 17, and the tax treaty tables in Pub 515 give the right rate.
The consequence of a missing W-8BEN-E LOB code is that the entity loses treaty benefits even if the country has a treaty with the United States. Henrik Larsen, a Danish dividend recipient, kept his 15 percent treaty rate under Article 10 of the U.S.-Denmark treaty only because his broker entered LOB code 02 (government) properly.
Common Chapter 3 Exemption Codes
Code 02 covers exemptions under the Internal Revenue Code other than treaty (for example, portfolio interest under IRC §871(h)), code 03 is income effectively connected, code 04 is exemption under a treaty, code 05 is the portfolio interest exemption, and code 06 is the qualified intermediary that assumes primary withholding responsibility. Code 22 covers QI Section 871(m) transactions, and code 24 covers payments to a foreign government.
The reason multiple codes exist is to track each statutory basis separately. The consequence of stacking the wrong code is that the IRS computer denies the exemption and bills 30 percent.
Chapter 4 Exemption Codes
Code 13 covers grandfathered payments, code 14 covers effectively connected income exempt from FATCA, code 15 covers payee-not-subject-to-Chapter-4-withholding (for example, an active NFFE), and code 16 covers excluded nonfinancial payments. The full list runs through code 24.
The plain meaning is that FATCA carve-outs require a separate code even if Chapter 3 already exempts the payment. The consequence of a blank Chapter 4 code on a Chapter-3-exempt payment is a system mismatch that holds up processing. Aiko Suzuki, a Japanese active business owner, kept her exemption only when the agent paired exemption code 04 (treaty) with Chapter 4 exemption code 15 (active NFFE).
Three Real-World 1042-S Scenarios
Below are three of the most common scenarios filers see, with the action and the consequence written out as they appear in IRS guidance.
Scenario 1: Canadian Consultant Paid for Services in the U.S.
| What the Agent Does | What Happens to Withholding |
|---|---|
| Collects W-8BEN claiming Article XIV of U.S.-Canada treaty, enters income code 17, exemption code 04, rate 0% | $0 withheld, treaty exemption granted, payee files Form 1040-NR for any U.S.-source connected income |
| Fails to collect W-8BEN, applies presumption rule | 30% withheld on gross fee, payee must claim refund through Form 1040-NR |
| Collects expired W-8BEN (over 3 years old) | Treaty denied, 30% withheld, agent liable if it knew the form was stale |
Scenario 2: German Shareholder Receiving U.S. Dividends
| What the Broker Does | What Happens to Withholding |
|---|---|
| Holds valid W-8BEN with Article 10 of U.S.-Germany treaty, uses income code 06, rate 15% | 15% withheld instead of 30%, recipient gets treaty rate |
| Receives W-8BEN-E from a German pension fund claiming 0% under Article 10(3)(b) | 0% withheld if LOB code 04 (tax-exempt pension trust) is entered |
| Has no W-8 on file | 30% withheld, no treaty, FATCA Chapter 4 also presumed if no GIIN |
Scenario 3: Indian Graduate Student on Scholarship
| What the University Does | What Happens to Withholding |
|---|---|
| Student gives W-8BEN claiming U.S.-India treaty Article 21, uses income code 16, exemption code 04 | 0% on the qualified scholarship portion, 14% on non-qualified portion |
| Student gives no W-8BEN | 14% on the entire taxable scholarship if F/J/M/Q visa, 30% otherwise |
| University miscodes as income code 20 (training) | Treaty denied because Article 21 governs scholarships, not training |
Concrete Examples With Named People
Anna Kowalski, a Polish ballet dancer, performs in three U.S. cities and earns $25,000. Her sponsor enters income code 19 (artists and athletes), no treaty exemption (the U.S.-Poland treaty caps the exemption at $20,000), and withholds 30 percent on the full $25,000 because Central Withholding Agreements were not negotiated in advance.
Rajiv Mehta, an Indian portfolio investor, earns $5,000 in U.S. bond interest. His broker uses income code 01 (interest paid by U.S. obligors) and Chapter 3 exemption code 05 (portfolio interest), so the withholding is zero, and box 13j is left blank because LOB does not apply to portfolio interest under IRC §871(h).
Beatriz Costa, a Brazilian software developer, sells a U.S. rental property for $400,000. The buyer must withhold 15 percent under FIRPTA and report the sale on Form 8288/8288-A, not Form 1042-S, but the rental income she received during the year does go on a 1042-S using income code 14 with a 30 percent rate because she did not file a §871(d) election.
Mistakes to Avoid When Filing Form 1042-S
- Using the wrong income code. Code 17 (independent services) is not interchangeable with code 16 (scholarship), and the consequence is a denied treaty claim and a CP-2100 notice.
- Leaving box 13b blank. A missing two-letter country code voids the recipient identification, and the IRS treats the payee as undocumented at 30 percent.
- Reporting net income in box 2. Box 2 must be gross, and net reporting causes box 7a not to reconcile against Form 1042 deposits.
- Reusing the Unique Form Identifier. A duplicated UFI corrupts amendments and the IRS rejects the second return outright.
- Skipping the Chapter 4 status. Chapter 3 and Chapter 4 boxes both need codes, and a blank Chapter 4 status triggers an automatic 30 percent FATCA layer.
- Filing one 1042-S for multiple income types. Each income code requires its own form, and bundling causes the IRS to allocate withholding to only one type.
- Missing the March 15 deadline. Late filings stack penalties under IRC §6721 on the IRS copy and §6722 on the recipient copy.
- Using paper when over the 10-return threshold. Treasury Decision 9972 requires e-filing, and paper filing draws a per-return penalty.
- Trusting an expired W-8. A W-8BEN expires after three calendar years, and an expired form means no treaty rate.
- Forgetting state tax boxes. California, New York, and Oregon impose their own withholding, and skipping boxes 17a–17c invites state penalties.
Do’s and Don’ts of Form 1042-S Filing
- Do collect a fresh W-8 before the first payment, because withholding decisions made without documentation default to the highest statutory rate.
- Do reconcile each 1042-S to Form 1042 deposits monthly, because end-of-year mismatches multiply the cleanup work.
- Do use IRIS or FIRE for any filer at the 10-return threshold, because paper triggers a separate penalty.
- Do issue Copy B to the payee by March 15, because foreign payees need it to claim treaty refunds on Form 1040-NR.
- Do keep documentation for at least three years, because the recordkeeping rule under Treas. Reg. §1.1461-1(c) supports your withholding decisions during audit.
- Don’t combine income types, because each code must have its own 1042-S.
- Don’t ignore Chapter 4 even if Chapter 3 exempts the payment, because FATCA layers on independently.
- Don’t backdate W-8 forms, because the IRS treats this as intentional disregard with a $680 per-return penalty.
- Don’t rely on a foreign passport alone for status, because the substantial presence test can convert the payee to a U.S. resident.
- Don’t forget the recipient TIN, because a missing TIN blocks treaty claims.
Pros and Cons of E-Filing 1042-S
- Pro: Faster processing, because IRIS posts within 48 hours and the recipient can claim treaty refunds sooner.
- Pro: Built-in validation, because IRIS rejects forms with missing or contradictory codes before they post.
- Pro: Free filing, because the IRIS Taxpayer Portal does not charge per return.
- Pro: Bulk upload, because CSV templates handle thousands of recipients in one transmission.
- Pro: Easier amendments, because the UFI and Original/Amended flag flow through the same system.
- Con: Software learning curve, because IRIS uses a new schema different from the legacy FIRE format.
- Con: Required transmitter control codes, because both FIRE and IRIS require pre-registration that takes weeks.
- Con: Strict 10-return threshold, because the rule under T.D. 9972 sweeps in tiny filers.
- Con: Mandatory two-factor authentication, because IRS sign-in security can lock out users mid-filing.
- Con: Limited paper fallback, because hardship waivers under Form 8508 are rarely granted.
QI, WP, and WT Frameworks
A Qualified Intermediary (QI) is a foreign financial institution that signs an agreement with the IRS to assume primary withholding and reporting responsibility. A Withholding Foreign Partnership (WP) and a Withholding Foreign Trust (WT) play similar roles for partnerships and trusts. These entities file 1042-S either on a recipient-specific basis or on a pooled basis using the Pro-Rata Basis Reporting indicator.
The reason the QI/WP/WT system exists is that it lets foreign banks act as a single point of contact between the IRS and many small foreign investors. The consequence of QI noncompliance is termination of the QI agreement, which forces the U.S. payer to revert to full statutory withholding. Yuki Watanabe and other clients of a Japanese QI saw their pooled treaty rates suspended for six months when the QI failed its periodic review under the 2022 QI Agreement.
Pooled Reporting vs. Recipient-Specific Reporting
A QI may report income paid to a withholding rate pool in which all account holders share the same Chapter 3 rate, status, and country. The plain meaning is that one Form 1042-S can represent dozens of investors. The consequence of using pooled reporting without satisfying the QI Agreement is that the IRS reclassifies the payments and demands recipient-specific 1042-S forms.
A common misconception is that pooled reporting hides identity. The QI still must perform Know-Your-Customer due diligence, must report U.S. account holders on Form 8966, and must produce documentation under audit.
Court Rulings and Enforcement Trends
In YA Global Investments LP v. Commissioner, 161 T.C. No. 11 (2023), the Tax Court held that a fund engaged in a U.S. trade or business owed §1446 withholding on foreign partner allocations, with reporting on Form 8804 and shadow reporting through 1042-S concepts. The case shows that ECI characterization can cascade into 1042-S liabilities for related FDAP allocations. The consequence is that fund managers cannot avoid withholding by recharacterizing as portfolio income.
The IRS has stepped up LB&I withholding compliance campaigns targeting Form 1042 underwithholding and 1042-S misreporting. Common audit findings include unreconciled deposits, missing GIINs, and stale W-8 forms. A common misconception is that the IRS does not match 1042-S to recipient returns; in fact, the IRS uses International Compliance Management Model data to flag mismatches.
Frequently Asked Questions
Is Form 1042-S the same as Form 1099?
No. Form 1099 reports U.S.-source income paid to U.S. persons, while 1042-S reports U.S.-source income paid to foreign persons under Chapter 3 or Chapter 4 withholding rules.
Do I need a U.S. taxpayer identification number to receive a 1042-S?
Yes. Most foreign payees need an ITIN, SSN, or EIN to claim treaty benefits, and box 13d must show that number or the treaty rate is denied.
Can I file Form 1042-S on paper if I have only one foreign payee?
Yes. A filer with fewer than 10 information returns of all types combined may paper file using Form 1042-T as the transmittal.
Does Form 1042-S report Social Security and Medicare tax?
No. FICA tax is reported on Form W-2, not 1042-S, and most nonresident aliens on F, J, M, or Q visas are exempt from FICA under IRC §3121(b)(19).
Must I issue a 1042-S if no tax was withheld?
Yes. A 1042-S is required even when withholding is zero because the payee claimed a treaty exemption, the portfolio interest exemption, or another statutory carve-out.
Can the recipient use Form 1042-S to claim a refund?
Yes. The foreign payee files Form 1040-NR and attaches Copy C of the 1042-S to claim the withholding credit shown in box 10.
Is there an extension to send the recipient copy?
Yes. The withholding agent may request a 30-day extension to furnish recipient copies by submitting a letter request to the IRS, separate from the Form 8809 extension for the IRS copy.
Does a Form 1042-S apply to crypto payments?
Yes. When a U.S. exchange pays staking rewards or interest to a foreign customer, the payment is U.S.-source FDAP and goes on a 1042-S using income code 23 (other income) until the IRS issues a specific code.
Do I need to file 1042-S for a payment under $600?
Yes. Unlike Form 1099 thresholds, 1042-S has no de minimis dollar threshold; even a $1 dividend to a foreign shareholder requires a form.
Can I correct a 1042-S after filing?
Yes. File an amended 1042-S with the AMENDED box checked and the same UFI as the original, and submit through the same channel (FIRE, IRIS, or paper) used for the original return.
Does Form 1042-S apply to U.S. citizens living abroad?
No. A U.S. citizen, even one residing overseas, is a U.S. person and receives Form W-2 or 1099, not 1042-S.
Are partnership ECI allocations to foreign partners reported on 1042-S?
No. Section 1446 allocations are reported on Form 8805 and summarized on Form 8804, but related FDAP items still go on 1042-S.
Related reading
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