This week IRS issued proposed regulations under the new Section 1446(f). Section 1446(f) requires withholding on the sale of a partnership interest, where the partnership is engaged in a U.S. trade or business and the transferor is a foreign person.
Guidance in the proposed regulations include:
Based on this guidance we can expect changes to some existing withholding forms and new forms to be added.
Stay tuned for more International tax updates as they are released! If you have any questions, please fill out the form below.