EYUS: Final regulations under Section 1446(f) set forth rules on withholding on transfers of partnership interests
|Tax Alerts, National/Federal Taxation, L ...|United States
The United States (US) Internal Revenue Service (IRS) has released final regulations (TD 9926) under Internal Revenue Code1 Section 1446(f), which imposes a new withholding tax on transfers by non-US persons of interests in partnerships that are engaged in a US trade or business. The final regulations retain the basic approach of the proposed regulations issued in May 2019 but make numer…
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