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Treasury Adds Color to Grecian Repeal - Proposed Regulations Implement New Section 864(c)(8) for Sale of Partnership Interests by Foreign Partners

USA - January 8 2019 On December 20, 2018, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed regulations (the...

Isaac L. Maron, Kenneth Klein, Michael Lebovitz, James R. Barry, Jared B. Goldberger.