The Operative Withholding Provision to New Section 864(c)(8): Meet New Section 1446(f)

By: Jerald David August, Chair, Fox Rothschild LLP International Taxation and Wealth Planning Group

The Internal Revenue Service recently issued proposed regulations, REG-10476-18, 2019-27 IRB 63, with respect to withholding and information reporting for certain dispositions of partnership interests by non-US persons who are partners in a partnership that is engaged in the conduct of a US trade or business. Under the Tax Cuts and Jobs Act, P.L.… Continue Reading