The U.S. IRS and Treasury have released proposed regulations on Withholding of Tax and Information Reporting with Respect to Interests in Partnerships Engaged in the Conduct of a U.S. Trade or Business (REG-105476-18). The regulations implement certain sections of the Internal Revenue Code (the Code), including sections added by the Tax Cuts and Jobs Act  (TCJA). Under Section 1446(f) of the Code as added by the TCJA, it is provided that if a portion of the gain (if any) on any disposition of an interest in a partnership would be treated under section 864(c)(8) as effectively connected with the conduct of...