Notice 2018-08 guidance on new section 1446(f) - KPMG United States
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Notice 2018-08: Revised timeline, guidance on implementing new section 1446(f)

IRS Notice 2018-08

The IRS today released an advance version of Notice 2018-08 that states the IRS and Treasury Department are suspending the application of new Code section 1446(f) in the case of a disposition of certain publicly traded partnership interests.


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New section 1446(f) was added to the Code by the recently enacted tax law. The tax legislation also added new section 864(c)(8).

Notice 2018-08 [PDF 20 KB]:

  • Provides background on new sections 864(c)(8) and 1446(f)
  • Describes the revised timeline for the application of new section 1446(f) to a disposition of certain interests in publicly traded partnerships
  • Requests comments and provides contact information 

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