Section 1446(f) Final Regulations: Key Changes to Guidance on Non-Publicly Traded Partnership Interest Transfers by Non-U.S. Persons
By EsqSocial Corporation 16/10/20
On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests by non-U.S. persons (the “Final Regulations”). The Final Regulations expand and modify proposed regulations that were published on May 13, 2019 (the “Proposed Regulations”), and which we described in a prior Tax Talks post. Unless otherwise...
By: Proskauer - Tax Talks