IIAC SUBMITS RECOMMENDATIONS ON PROPOSED REGULATIONS UNDER SECTION 1446(F) OF THE INTERNAL REVENUE CODE
On August 6, 2020, the IIAC submitted priority recommendations to the Internal Revenue Service (IRS) and U.S. Department of the Treasury in respect of proposed regulations under section 1446(f) of the U.S. Internal Revenue Code which will impose a withholding tax on non-U.S. partners that sell interests in such partnerships to the extent the gain is allocable to the partnership’s U.S. business assets. These regulations impact IIAC Member Firms who may be required to complete withholding and reporting to the IRS on behalf of their clients. Without additional guidance or amendments, the proposed regulations under section 1446(f) create substantial additional burdens for firms. The IIAC had previously provided comments on the proposed regulations on July 12, 2019 and provided additional comments in order to highlight the outstanding concerns that impact the administrability of the requirements.
For more information, please contact Adrian Walrath.