The Final Regulations generally retain the basic approach and structure of the Proposed Regulations, with notable exceptions as discussed below. Generally, upon a foreign person’s disposition of a partnership interest, the transferee is required to withhold a tax of 10-percent of the amount realized on the disposition. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section 1446(f) of the Internal Revenue Code (the “Code”) on the sale, exchange or redemption of a partnership interest held by a foreign person, making important changes to regulations that were proposed on (the “Proposed Regulations”). Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations ( T.D. TREASURY AND THE IRS FINALIZE REGULATIONS ON WITHHOLDING ON THE DISPOSITION OF A PARTNERSHIP INTEREST BY A FOREIGN PARTNER
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