EYUS: Final regulations largely adopt proposed characterization of foreign persons’ gain or loss from sale or exchange of interests in certain partnerships, with some welcome changes
|Tax Alerts, National/Federal Taxation, L ...|United States
Executive summary
On 21 September 2020, the United States (US) Treasury Department and the Internal Revenue Service (IRS) released final regulations (T.D. 9919) under Internal Revenue Code1 Section 864(c)(8) that provide guidance for determining the treatment of gain or loss recognized by a foreign person on the sale of an interest in a partnership that is engaged in the conduct of a…
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