Another Chapter in the Effectively Connected Income Saga—IRS Issues Proposed Regulations on Sales of Partnership Interests by Foreign Partners
▪ Written by Edward Tanenbaum, Daniel Reach and Seth Buchwald
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. [...]Read more