Hold Up, Partner: Proposed Regulations Address Withholding on Foreign Partner Dispositions

June 17, 2019 By Edward Tanenbaum and Heather Ripley

Newly proposed regulations expand withholding on foreign partners transferring interests in partnerships who do business in the United States. Our International Tax Group evaluates the tightening reins on exceptions.

Notice 2018-29 and other prior Section 1446(f) guidance
Modified withholding exceptions in the new regulations
Activation of previously suspended PTP and secondary withholding

Read the full advisory here.

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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 Heather Ripley

Heather Ripley is an associate in the firm’s Federal & International Tax Group. Her practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals.

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