US: Proposed regulations would coordinate tax withholding and gain deferral for certain foreign persons and partnerships investing in qualified opportunity funds, clarify working capital safe harbor
The United States (US) Internal Revenue Service (IRS) released proposed regulations (REG-121095-19) that would allow certain non-US persons and non-US-owned partnerships, including private equity, real estate, and other alternative and private capital funds, to reduce or eliminate withholding imposed under Internal Revenue Code1 Sections 1445, 1446(a) and 1446(f) on eligible gains deferr…
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