Date: 2020-11-30
Links to Federal Register: HTML, PDF
(Proposed Regulation: REG-105476-18 HTML, PDF)
Document Number: 2020-22619, RIN: 1545-BO60
Action: Final rule.
Abstract: This document contains final regulations that provide guidance related to the withholding of tax and information reporting with respect to certain dispositions of interests in partnerships engaged in a trade or business within the United States. The final regulations affect certain foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in a trade or business within the United States, and persons that acquire those interests. The final regulations also affect partnerships that, directly or indirectly, have foreign persons as partners.
| Notable phrases | Frequency |
|---|---|
| publicly traded partnership(s) | 143 |
| required to withhold | 64 |
| (sale|transfer) of a PTP interest | 45 |
| exception to withholding | 44 |
| subject to withholding | 31 |
| effectively connected gain | 27 |
| may rely on a certification | 25 |
| amount realized (from|on) the transfer | 23 |
| effectively connected with the conduct | 22 |
| engaged in a trade or business | 22 |
| primary withholding responsibility | 22 |
| certification of non-foreign status | 21 |
| books and records | 20 |
| partnership that is a transferee | 16 |
| certification from the transferor | 13 |
| transfer of a partnership interest | 12 |
| certification is incorrect or unreliable | 12 |
| amount required to be withheld | 10 |
| may not rely on a certification | 9 |
| knows, or has reason to know | 9 |
| would have been effectively connected | 7 |
| statement required to be furnished | 7 |
| Reg. Cites | Frequency |
|---|---|
| 1.1446(f)-2 | 28 |
| 1.1446(f)-3 | 26 |
| 1.1446(f)-4 | 21 |
| 1.1446-4 | 17 |
| 1.1446(f)-5 | 16 |
| 1.1446(f)-2(d)(2) | 11 |
| 1.1446-1 | 10 |
| 1.1446-7 | 10 |
| 1.1446(f)-1 | 10 |
| 1.1446(f)-2(c)(2)(iv) | 8 |
| 1.1446(f)-3(a)(1) | 7 |
| 1.1446-3 | 7 |
| 1.1446(f)-2(b)(5) | 6 |
| 1.1446(f)-2(b) | 6 |
| 1.1446-3(c)(4) | 6 |
| 1.1446(f)-2(a) | 6 |
| 1.1446(f)-4(a) | 6 |
| 1.1446-4(b)(3) | 5 |
| 1.1446(f)-2(c)(4) | 5 |
| 1.1446-4(b)(4) | 5 |
| Sec. Cites | Frequency |
|---|---|
| 1446(f) | 98 |
| 864(c)(8) | 60 |
| 1446(a) | 39 |
| 1446(f)(4) | 37 |
| 1446(f)(1) | 33 |
| 1446 | 16 |
| 1461 | 16 |
| 1441 | 15 |
| 751 | 12 |
| 33 | 7 |
| 1445 | 7 |
| 1445(e)(1) | 5 |
| 6045 | 5 |
| 267(b) | 4 |
| 11(b) | 4 |
| 1445(e)(1) | 4 |
| 897 | 4 |
| 3406 | 3 |
| 671 | 3 |
Statistics
Number of pages: 38, words: 41,999, sentences: 1,335
Average words per sentence: 31