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Section 1061 Final Regulations on the Taxation of Carried Interest

On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) providing guidance on Section 1061 of the Internal...more

Section 1446(f) Final Regulations: Key Changes to Guidance on Non-Publicly Traded Partnership Interest Transfers by Non-U.S....

On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more

Tax Reform – I.R.S. Updates Withholding Tax Guidance on Sales of Partnership Interests

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

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