The guidance shows Treasury Regulations will ease administrative challenges and exclude certain transfers from the new withholding regime.

Key Points:

..Taxpayers can deliver IRS Form W-9 or an affidavit to establish the taxpayer is not a foreign person.

..No withholding is required if no gain is recognized or if ECI is less than 25% of the total gain.

..Procedures are established to identify the amount of partnership liabilities taken into account.

..Partnerships are not required to withhold under Section 1446(f)(4) until future guidance is issued.