IRS Guidance Fills Out Grecian Magnesite's Statutory Repeal
By JoonBeom Pae, Kenneth Klein, James Barry and Isaac Maron (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. 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. 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 they would prospectively be effective as of Dec. 20, 2018. This article provides an overview of certain aspects of the proposed regulations....
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