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KPMG report: Initial impressions of proposed regulations under section 864(c)(8)

Initial impressions of proposed regulations

The U.S. Treasury Department and IRS released a version of proposed regulations (REG-113604-18) as guidance under section 864(c)(8) concerning tax on the sale of U.S. trade or business partnership interests on a look-through basis.

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Section 864(c)(8) was added to the Code by the new U.S. tax law (Pub. L. No. 115-97, date of enactment December 22, 2017)—the law that is at times referred to as the “Tax Cuts and Jobs Act” (TCJA).

Read the proposed regulations [PDF 150 KB] (36 pages)

For the full report, read TaxNewsFlash

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