EYUS: Final regulations under Section 1446(f) set forth rules on withholding on transfers of partnership interests
|Tax Alerts, National/Federal Taxation, L ...|United States
The United States (US) Internal Revenue Service (IRS) has released final regulations (TD 9926) under Internal Revenue Code1 Section 1446(f), which imposes a new withholding tax on transfers by non-US persons of interests in partnerships that are engaged in a US trade or business. The final regulations retain the basic approach of the proposed regulations issued in May 2019 but make numerous changes to specific rules in response to comments received.
Background
The Tax Cuts and Jobs Act (…