Foreign Stakeholders in U.S. Partnerships Get More Tax Clarity

Foreign investors have guidelines on how a new tax will apply to their gain from the sale of U.S. partnership interests.

But the Internal Revenue Service left U.S. partners wondering how the tax will actually be collected.

The IRS and Treasury Department on Dec. 20 proposed regulations (REG-113604-18) under new tax code Section 864(c)(8), which applies to foreign investors upon sale, disposition, or exchange of U.S. partnership shares made on or after Nov. 26, 2017.

The rules lay out operational guidelines for determining what gains and losses are liable for the tax, while additional rules under ...