The U.S. Treasury Department and IRS today released for publication in the Federal Register proposed regulations (REG-105476-18) concerning tax withholding and information reporting with respect to certain dispositions of interests in partnerships engaged in the conduct of a trade or business within the United States.
The proposed regulations [PDF 409 KB] reflect measures enacted by the 2017 tax law (Pub. L. No. 115-97, that is often referred to as the “Tax Cuts and Jobs Act”) and affect certain foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in the conduct of a trade or business within the United States, and persons that acquire those interests.
The proposed regulations also affect partnerships that, directly or indirectly, have foreign persons as partners.
In brief, these proposed regulations (according to the preamble):
The proposed regulations are scheduled to appear in the Federal Register on May 13, 2019. Comments and requests for a public hearing are due 60 days after May 13, 2019.
The purpose of this report is to provide text of these proposed regulations. Initial impressions about these proposed regulations will be provided in a future edition of TaxNewsFlash.
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