EYUS final regulations issued for qualified foreign pension funds contain some favorable clarifications
|Tax Alerts, National/Federal Taxation, A ...|United States
Executive summary
In final regulations (T.D. 9971) (the Final Regulations) published 29 December 2022, the United States (US) Treasury Department (Treasury) and Internal Revenue Service (IRS) addressed the qualification for the exemption from taxation under Internal Revenue Code1 Section 897(l) for gain or loss attributable to the disposition of US real property interests (USRPIs) held by qual…
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