Forms W-8 and their accompanying instructions (excluding Form W-8EXP) were updated (Rev. The provisions of the section 1446(f) regulations relating to withholding and reporting on transfers of interests in partnerships that are not PTPs generally apply to transfers occurring after January 29, 2021. Withholding on transfers of interests in PTPs and the revisions included in the section 1446(f) regulations relating to withholding on PTP distributions under section 1446(a) apply to transfers and distributions that occur on or after January 1, 2023. The section 1446(f) regulations also revise certain requirements under section 1446(a) relating to withholding and reporting on distributions made by PTPs, and expand the entities permitted to act as nominees for PTP distributions to include certain qualified intermediaries (QIs) and certain U.S. 9926 (84 FR 76910), published on November 30, 2020, contains final regulations (section 1446(f) regulations) relating to the withholding and reporting requirements under section 1446(f), including those that apply to brokers effecting transfers of interests in publicly traded partnerships (PTPs). Section 1446(f) generally applies to transfers occurring on or after January 1, 2018. transferor must withhold a tax equal to 10% of the amount realized on the disposition unless an exception to withholding applies. The Tax Cuts and Jobs Act (TCJA) added section 1446(f), which generally requires that if any portion of a gain on any disposition of an interest in a partnership would be treated under section 864(c)(8) as effectively connected gain, the transferee purchasing an interest in such a partnership from a non-U.S.
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