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ON DEMAND: International Tax Series: Withholding on Transfers of ECI Partnership Interests After the Proposed Regulations
Credit: 0 Credit Hours
Run Time: 85 Minutes
Section 1446(f) imposes withholding on certain transactions involving interests in partnerships that are engaged in a U.S. trade or business. The government has issued proposed regulations - as well as two Notices - under the provision, but a number of practical issues and uncertainties remain. The panel will discuss the impact of sections 864(c)(8) and 1446(f), as well as the questions and traps for the unwary that arise under the Notices and proposed regulations.
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- Josh Kaplan; KPMG
- Steven Gilbert; Deloitte
- Jonathan Jackel; EY
- Subin Seth, Senior Counsel, IRS Office of Chief Counsel
|D.C. Bar Member||$40.00|
|D.C. Bar Premium Community Member||$0.00|
|Law Student Community||$15.00|
|Non Profit Attorney||Standard|