Thus, many of the operational challenges noted by industry at the time of the proposed regulations remain in the final regulations, a number of these having to do with how section 1446(f) would work with intermediaries and flow-through entities like partnerships. The exceptions to section 1446(f) withholding remain roughly the same as in the proposed regulations (with a few tweaks), and PTP distributions remain subject to both existing section 1446(a) withholding and new withholding under section 1446(f). ![]() Moreover, nonqualified intermediaries still will not be allowed to reduce section 1446(f) withholding by providing documentation of their underlying beneficial owners (even if some are U.S. A key item is that there is no exemption for DVP trades. And while the IRS has provided some flexibility with respect to qualified intermediaries that receive payment on PTP transfers, a number of industry requests for modifications to the proposed rules was not incorporated into the final regulations. Overall, the section 1446(f) withholding regulations follow the framework of the proposed regulations issued last year. Such sales or dispositions are also subject to withholding under section 1446(f). partner of an interest in a partnership that engaged in a U.S. ![]() Under Internal Revenue Code section 864(c)(8) enacted as part of the Tax Cuts and Jobs Act in 2017, gain or loss on the sale, exchange or disposition by a non-U.S. On Octothe IRS released final regulations governing withholding rules for transfers of partnership interests by non-U.S.
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