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

Written by and

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.