IRS Issues Final Regulations on Withholding Requirements for Partnerships with Foreign Partners
May 13, 2008
Andrew M. Short and Matthew G. Brigham
On April 28, 2008, the Treasury Department and the Internal Revenue Service (the IRS) issued final regulations (the final regulations) regarding when a partnership may take partner level deductions and losses into account in determining the partnerships obligation to pay a withholding tax based on the foreign partners allocable share of the partnerships effectively connected taxable income. The final regulations replace temporary regulations that were published on May 18, 2005 (the temporary regulations).