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IRS Withholding Tax Guidance Helpful, But Not Perfect

As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests....more

Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

Foreign Partner Not Taxable on Partnership Sale

Private equity and venture capital funds often invest in portfolio companies that are formed as partnerships or limited liability companies. But these investments create certain problems for foreign limited partners (LPs) in...more

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