On 6 November 2020, final and temporary regulations (TD 9919) from the U.S. IRS and Treasury were published in the Federal Register with guidance on determining the amount of gain or loss treated as effectively connected with the conduct of a trade or business within the United States. The final and temporary regulations affect foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in a U.S. trade or business, as well as partnerships that, directly or indirectly, have foreign persons as partners. The regulations implement Section 864(c)(8) of...