According to the IRS web page dealing with Effectively Connected Income, for a foreign individual, "Income from the rental of real property may be treated as ECI if the taxpayer elects to do so."
I assume that means the individual has the option to call the income ECI as opposed to FDAP income, which is taxed at 30% or 37%.
First, how wrong am I?
Second, if an individual can elect to have what would be considered rental FDAP income to be ECI, can a foreign partner in a domestic partnership do that too?
Thanks for any clarification you can give me.