Proposed Regulations Under Section 1446(f) Miss the Donut
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Proposed Regulations Under Section 1446(f) Miss the Donut Contributor(s) On May 7, 2019, the IRS released proposed regulations under §1446(f) (the “Proposed Regulations”), which requires withholding of U.S. tax on certain dispositions of interests in partnerships conducting a U.S. trade or business. The withholding rule of §1446(f) enforces the substantive tax rule of §864(c)(8). Both rules were enacted by the Tax Cuts and Jobs Act. More from the Weil Tax Blog Copyright © 2019 Weil, Gotshal & Manges LLP, All Rights Reserved. The contents of this website may contain attorney advertising under the laws of various states. Prior results do not guarantee a similar outcome. Weil, Gotshal & Manges LLP is headquartered in New York and has office locations in Beijing, Boston, Dallas, Frankfurt, Hong Kong, Houston, London, Miami, Munich, New York, Paris, Princeton, Shanghai, Silicon Valley, Warsaw, and Washington, D.C. |