Final IRS rules are meant to show foreign investors how a new tax created in the 2017 overhaul will affect gain from the sale of U.S. partnership interests.
The IRS issued the rules (T.D. 9919, RIN: 1545-BO86) on Monday, following their proposal in 2018.
The rules fall 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 provision was created in the 2017 tax law.
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