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foreign partnerships

International Tax ADVISORY: Section 721(c) Partnership Regulations Arrive Just in Time

February 15, 2017 By Edward Tanenbaum and Heather Ripley

On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some alterations, these regulations deliver on guidance announced in Notice 2015-54, released in August 2015 (see our prior coverage of Notice 2015-54 here). The regulations incorporate a number of taxpayer-friendly updates in response to comments on the Notice. The prospect of further direction in this area, however, including guidance under Sections 482 and 6662 as described in the [...]Read more

Filed Under: Federal Tax Advisory Tagged With: ECI, effectively connected income, FIRPTA, Foreign Investment in Real Property Tax Act of 1980, foreign partnerships, IRS, Notice 2015-54, Section 6662, Section 721(c), Sections 482, T.D. 9814, Taxpayer Relief Act of 1997, Treasury

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