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The Tax Cuts and Jobs Act (“TCJA”) imposed tax on gains derived from the disposition of interests in partnerships carrying on a US trade or business. To enforce this new regime against foreign partners, the TCJA also introduced a new withholding tax regime, Section 1446(f). Under this withholding regime, the purchaser...
The IRS Large Business & International (“LB&I”) division recently announced three new compliance campaigns affecting transfer pricing. The goal of LB&I’s new campaigns is to improve return selection, identify issues representing non-compliance risks and ensure the efficient use of limited resources. The compliance campaigns are: Captive Services Provider Campaign – This campaign concerns arm’s length...
