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Proposed regulations, withholding obligations incident to transfers of interests by foreign partners

Transfers of interests by foreign partners

The U.S. Treasury Department and IRS on Tuesday afternoon, May 7, 2019, released for publication in the Federal Register proposed regulations addressing withholding obligations incident to transfers of interests by foreign partners in partnerships that engage in a U.S. trade or business. The proposed regulations primarily are issued pursuant to authority contained in sections 864(c)(8) and 1446(f).

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Read the text of the proposed regulations [PDF 476 KB] (116 pages) as released for publication in the Federal Register.


Read a KPMG report (May 2019) [PDF 352 KB] that provides initial impressions and observations about these proposed regulations: KPMG report: Proposed regulations, withholding obligations incident to transfers of interests by foreign partners in partnerships engaged in U.S. trade or business

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