IRS Issues Proposed Regulations Regarding Withholding Under Section 1446(f)

On May 7, 2019, the US Treasury Department and the Internal Revenue Service (the “IRS”) released proposed regulations regarding Section 1446(f) of the Internal Revenue Code of 1986, as amended (the “Code”) regarding withholding obligations related to certain transfers of interests in partnerships engaged in a US trade or business.  This Legal Update is intended to provide an overview of the proposed rules for withholding, reporting and paying tax under Section 1446(f).