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IRS Issues Guidance on Transfers by Non-US Partners of Interests in Partnerships With US Assets

Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partner’s effectively connected gains or losses from a transfer of its interest in a partnership engaged in a US trade or...more

Qualified Opportunity Funds: Investment and Structuring Considerations

Recent guidance from Treasury clarifies fundamental aspects regarding the investment of deferred capital gains in QOFs. Key Points: ..Investors in qualified opportunity funds may derive significant tax benefits in the...more

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