Alston & Bird Tax Blog

Another Chapter in the Effectively Connected Income Saga—IRS Issues Proposed Regulations on Sales of Partnership Interests by Foreign Partners

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The IRS gets granular on new Section 864(c)(8), created by the Tax Cuts and Jobs Act. Our International Tax Group examines the implications of the newest proposed regulations brought on by tax reform.

  • How Section 864(c)(8) codifies longstanding IRS principles on effectively connected income
  • The proposed regulations’ complex formula for deemed partnership asset sales
  • Application to tiered partnerships and treaties

Read the full advisory here.

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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About Daniel Reach

Danny Reach is an associate in the Federal and International Tax Group. His practice includes federal and international tax planning, and he has particular experience with the tax aspects of derivative financial instruments.

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About Seth Buchwald

Seth Buchwald is an associate in the Federal & International Tax Group. He uses his experience as a former certified public accountant (CPA) to understand and assist clients with their complex domestic and international tax planning and structuring issues.

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