The United States (US) Internal Revenue Service (IRS) has released final regulations (TD 9926) under Internal Revenue Code1 Section 1446(f), which imposes a new withholding tax on transfers by non-US persons of interests in partnerships that are engaged in a US trade or business. The final regulations retain the basic approach of the proposed regulations issued in May 2019 but make numerous changes to specific rules in response to comments received.BackgroundThe Tax Cuts and Jobs Act (TCJA) settled an ongoing dispute about whether nonresident aliens and foreign corporations not otherwise engaged in a US trade or business were subject to US tax...