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federal_register: E8-9356

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
E8-9356 Special Rules To Reduce Section 1446 Withholding Rule This document contains final regulations regarding when a partnership may consider certain deductions and losses of a foreign partner to reduce or eliminate the partnership's obligation to pay withholding tax under section 1446 on effectively connected taxable income allocable under section 704 to such partner. The regulations will affect partnerships engaged in a trade or business in the United States that have one or more foreign partners. The final regulations also include conforming amendments to Sec. Sec. 1.1446-3 and 1.1446-5 and to regulations under sections 1464, 6071, 6091, 6151, 6302, 6402, 6414, and 6722. 2008-04-29 2008 4 https://www.federalregister.gov/documents/2008/04/29/E8-9356/special-rules-to-reduce-section-1446-withholding https://www.govinfo.gov/content/pkg/FR-2008-04-29/pdf/E8-9356.pdf Treasury Department; Internal Revenue Service 497,254 This document contains final regulations regarding when a partnership may consider certain deductions and losses of a foreign partner to reduce or eliminate the partnership's obligation to pay withholding tax under section 1446 on effectively connected... 1545-BD80

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