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Sales of U.S. Partnership Interests by Foreign Partners: New Sections 864(c)(8) and 1446(f)

Gain insight into how to minimize the impact for clients buying or selling a partnership interest.Following the enactment of section 1446(f), buyers of U.S. partnership interests may be required to withhold a certain amount of the sales proceeds and deposit the amounts with the IRS. These withholding and reporting obligations are new and continue to evolve as Treasury and the IRS release more guidance. This topic will discuss the legal background of these new rules, demonstrate how they apply in practice, and discuss methods to minimize the impact for clients buying or selling a partnership interest.
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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Background
  • Rev. Rul. 91-32
  • Grecian Magnesite
  • TCJA: New Sections 864(c)(8) and Section 1446(f)
  • Guidance to Date
Determining Gain or Loss
  • Calculation Mechanics
  • Determination of Distributive Share
  • Coordination With FIRPTA
Withholding
  • General Withholding Requirements
  • Exceptions
  • Documentation
Advising Buyers and Sellers of Partnership Interests
  • Considerations for Buyers
  • Considerations for Sellers
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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • NY CLE 2.0
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • NY CLE 2.0
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Jared Binstock

Jared Binstock

Skadden, Arps, Slate, Meagher & Flom LLP

  • Associate in the Washington, D.C. office of Skadden, Arps, Slate, Meagher & Flom LLP
  • Advises public and private companies on a broad range of domestic and international U.S. federal income tax issues, with particular focus on joint ventures, M&A and restructuring transactions, information reporting and tax equity financings
  • Regularly counsels clients on the various U.S. and international information reporting and withholding requirements
  • Can be contacted at [email protected]
No photo available

Joshua G. Rabon

Skadden, Arps, Slate, Meagher & Flom LLP

  • Associate in the Washington, D.C. office of Skadden, Arps, Slate, Meagher & Flom LLP
  • Advises public and private companies on a broad range of domestic and international U.S. federal income tax issues, with particular focus on international joint ventures, M&A and integration and restructuring transactions
  • Practice includes significant work on the various U.S. and international information reporting and withholding requirements
  • Before joining Skadden, worked at the IRS Office of Associate Chief Counsel (international) on numerous regulations and other guidance projects, including guidance under section 1446(f)
  • Can be contacted at [email protected]
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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 406724
Published 2019
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