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• 06/14/2019
  International Tax Alert: Withholding Tax on Sales of Partnership Interests by Foreign Person(s)

  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...

• 05/08/2019
  IRS Campaign Shifts the Focus to Transfer Pricing

  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...