On May 7, 2019, the U.S. Treasury proposed new federal income tax regulations (REG-105476-18) to provide additional guidance on a new partnership rule enacted in the Tax Cuts and Jobs Act of 2017. This could potentially affect partnerships (or limited liability companies taxed as partnerships) doing business in the U.S. (“ETB Partnerships”) as well as private equity funds that have direct or indirect foreign investors. The Alert can be found here.
Client Alert: Proposed Income Tax Regulations May Affect Private Equity Funds and Other Partnerships that Have Direct or Indirect Foreign Investors
