The US Department of the Treasury and Internal Revenue Service (IRS) recently issued final regulations under section 1446(f), a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that generally imposes a...more
Since 2018, the buyers, sellers, and partnerships engaging in secondary and other transactions involving partnership interest transfers have been navigating complicated U.S. tax and related withholding obligations that apply...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 28, 2020 – October 2, 2020... October 7, 2020: The IRS published final regulations...more
Proposed regulations have recently been issued by the U.S. Internal Revenue Services (IRS) under a withholding provision of U.S. tax law enacted in 2017 that imposes withholding tax on a non-U.S. person’s sale (or other...more
The U.S. federal taxation of non-U.S. persons who transfer interests in partnerships has a long and storied history. The government staked out its position in 1991, effectively providing that a non-U.S. partner should be...more
1. Types of Business Entities - The main business entities in Greece are the following: i) the Société Anonyme (S.A.); ii) the Private Company (P.C.); iii) the Limited Liability Company (Ltd); iv) the General Partnership...more
On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-29 (the “Notice”), announcing the intention of the IRS and the Department of the Treasury to issue regulations regarding the withholding requirements...more
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
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
In This Issue: - Two Combined Reporting Decisions Highlight Issues Involving “Permissive” Combined Reporting - New York State Corporate Tax Reform Legislation Enacted – What You Need to Know - Appellate Court...more