IRS Guidance Fills Out Grecian Magnesite's Statutory Repeal

Law360 (January 22, 2019, 6:09 PM EST) -- On Dec. 20, 2018, the U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations on the treatment of a foreign partner’s transfer of an interest in a partnership that is engaged in the conduct of a trade or business in the United States.[1] The proposed regulations provide much-awaited guidance to Internal Revenue Code Section 864(c)(8), a new code section introduced by the 2017 Tax Cuts and Jobs Act.[2] If the proposed regulations are finalized by June 22, 2019, then they would be retroactively effective as of Nov. 27, 2017. If they are not finalized by such date, then...

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