Partnership Buyers, Beware IRS Withholding Proposal

By John Harrington, Jon Hutchens, Timothy Santoli and Ryan Zucchetto (May 20, 2019, 4:31 PM EDT) -- On May 7, 2019, the Internal Revenue Service issued proposed regulations that provide guidance for provisions enacted as part of the Tax Cuts and Jobs Act. The 2017[1] provisions impose U.S. income tax on non-U.S. partners selling interests in partnerships that are considered to be engaged in the conduct of a trade or business in the United States and impose withholding obligations on buyers of such interests....

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