The U.S. Internal Revenue Service issued proposed regulations under the Internal Revenue Code section 1446 regarding the determination, reporting and collection of withholding taxes on the effectively connected taxable income (ECTI) of the U.S. and foreign partnerships with foreign partners. Pursuant ...
On Tuesday, May 7, the Internal Revenue Service (IRS) released proposed regulations under Section 1446(f) of the Internal Revenue Code of 1986, as amended (the Code),1and certain related Sections (the Proposed Regulations). The Proposed Regulations would supersede existing interim guidance...
the transferor must certify that ordinary income attributable to property described in Code section 751 (“hot assets”) utilized in or attributable to a US trade or business would not be recognized in connection with the transfer.