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.
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