Multi-member LLC with foreign investors - tax questions

[Satha Palani]

I Have a very specific question with regards to foreign investors and taxation.

2 friends of mine are keen to invest in a piece of real property here in the US. The plan is to form a multi-member LLC as a vehicle to own the property, with all 3 of us being members. I will retain a 10% interest in return for management services. They will own the rest.

My question is, if we elect to to treat the LLC as a partnership for taxation purposes, will the income from the property still be subject to the 30% withholding rule?

From reading the IRS documentation, it sounds like the 30% withholding only applies to foreign persons who owns the property individually.

appreciate anyone with experience / knowledge weighing in

thanks