Alston & Bird Tax Blog

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

By and

The IRS gives taxpayers a bit more direction on two provisions of the Tax Cuts and Jobs Act already in force. Our International Tax Group breaks down the new guidance for the repatriation tax and foreign partner withholding.

  • Notice 2018-26 previews anti-avoidance and other rules under Section 965
  • Notice 2018-29 moves ahead with withholding for non-publicly traded partnerships under Section 1446(f)

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 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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