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Withholding obligations incident to transfers of interests by foreign partners

Final regulations released to Federal Register

The U.S. Treasury Department and IRS today released for publication in the Federal Register final regulations (T.D. 9926) concerning the withholding obligations incident to transfers of interests by foreign partners in partnerships that engage in a U.S. trade or business.

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Read the final regulations [PDF 405 KB] (38 pages as published in the Federal Register on November 30, 2020)

Read an October 2020 report [PDF 972 KB] prepared by KPMG LLP, providing initial impressions about key provisions addressed by these final regulations (this report is based on a version of the final regulations posted by the IRS to its website on October 7, 2020).

Comparison against advance version of final regulations

As noted above, the IRS on October 7, 2020, posted to its website a version of these final regulations that includes the following statement:

This document will be submitted to the Office of the Federal Register (OFR) for publication and will be pending placement on public display at the OFR and publication in the Federal Register. The version of the final regulations released today may vary slightly from the published document if minor editorial changes are made during the OFR review process. The document published in the Federal Register will be the official document.

Read a computer-generated document [PDF 1.5 MB] that provides a comparison of the version of the final and temporary regulations submitted today for publication in the Federal Register against the version posted by the IRS on October 7, 2020. This unofficial document was produced by KPMG for the purpose of showing what changes, if any, were made to the regulations prior to being released to the Federal Register for publication. It has not been reviewed for accuracy.

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

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