IRS proposes new partnership audit rules for international issues
TAX ALERT |
On Nov. 30 the IRS published Proposed Regulation REG-119337-17, which contains extensive and highly detailed rules addressing how the new partnership audit rules will apply to foreign partners, partnerships and payments involving foreign persons, and how those rules will interact with other substantive and procedural rules affecting partnerships with foreign partners or payments involving foreign persons. The proposed regulations include rules relating to the withholding of tax on foreign persons, withholding of tax to enforce reporting on certain foreign accounts and the treatment of creditable foreign tax expenditures of a partnership.
The IRS is seeking comments on various provisions of the proposed regulation. Submitted comments can be found here.