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PwC comment letter on proposed regulations under Section 1446(f)

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July 2019


PwC submitted a comment letter on July 12 regarding the proposed regulations under Section 1446(f) that address tax withholding and information reporting on partnerships with a US trade or business. Section 1446(f) was enacted as part of the 2017 tax reform act, and the proposed regulations were issued on May 13, 2019 (see PwC Tax Insight). 

The comment letter requests that the final regulations clarify that the 10-percent exception set forth in Prop. Reg. sec. 1.1446(f)-4(b)(3) apply to a publicly traded partnership (PTP) that owns US real property interests (within the meaning of Section 897(c)) if such PTP is not engaged in the conduct of a trade or business within the US without regard to Section 897.

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Kevin Brown

Principal, Tax Controversy and Regulatory Services Leader, PwC US

David Hall

Mergers & Acquisitions (M&A) Tax Leader, PwC US

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