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IRS Proposes Regulations for Withholding on Transfers of Partnership Interests

The US Internal Revenue Service (IRS) issued proposed regulations on May 7 that would expand tax withholding and reporting requirements in certain sales or exchanges of interests in partnerships engaged in one or more US...more

IRS Issues Withholding Guidance on Transfers of Non-Publicly Traded Partnership Interests by Non-US Persons

The Internal Revenue Service announces forthcoming regulations in relation to “ECI withholding” under Section 1446(f). It also announces interim relief and guidance for taxpayers pending regulations....more

M&A and Tax Reform—New Tax Considerations with Wide-Ranging Implications

New tax provisions have significant impact on structuring mergers and acquisitions. In light of the recent passage of HR 1 (the Act) and ensuing sweeping changes to tax law in the United States, certain tax-related aspects...more

Tax Reform Legislation Reverses Grecian Magnesite Mining, Adds New Withholding Tax

New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions. On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more

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