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U.S. IRS and Treasury Issue Correcting Amendments to Regulations on Special Rules to Reduce Section 1446 Withholding

12 June 2020

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Approved Changes

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United States

The U.S. IRS and Treasury have issued correcting amendments to Treasury Decision (TD) 9394 of 29 April 2008 on Special Rules To Reduce Section 1446 Withholding. The correcting amendments were published in the Federal Register on 11 June 2020 and apply from 29 April 2008. --- SUMMARY: This document contains corrections to Treasury Decision 9394, which was published in the Federal Register on Tuesday, April 29, 2008. Treasury Decision 9394 contained final regulations regarding when a partnership may consider certain deductions and losses of a foreign partner to reduce or eliminate the partnership's obligation to pay withholding tax under section...