Final regulations - Foreign partner’s U.S. tax liability on transfer of partnership interest

Given the overall development of the secondaries market and the increasing volume and size of secondary funds, the U.S. tax and withholding regime that applies to a foreign partner transferring an interest in a partnership that is engaged in a U.S. trade or business, enacted as part of 2017 U.S. tax reform, has become an important consideration in structuring and negotiating secondary transactions, even those transactions that do not involve U.S. investments.

Languages English
Topics Tax
Countries United States

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