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.

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