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U.S. IRS Issues Final Regulations on Transfers of Certain Property by U.S. Persons to Partnerships with Related Foreign Partners

23 January 2020

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Approved Changes

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United States

The U.S. IRS and Treasury have issued final regulations (TD 9891) on transfers of certain property by U.S. persons to partnerships with related foreign partners. The regulations contain rules to counter abusive transfers of appreciated property to foreign related partners and are generally effective on the date published in the Federal Register, 23 January 2020. --- SUMMARY: This document contains final regulations that provide guidance applicable to transfers of appreciated property by U.S. persons to partnerships with foreign partners related to the transferor. Specifically, when a U.S. person transfers appreciated property to a partnership with a foreign partner related to...