16
Jul
By Alan Winston Granwell, William M. Sharp, Robert G. Lorndale, Christopher Fiore Marotta | Holland & Knight
In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S. persons owning stock of foreign corporations through domestic partnerships.
The New Guidance will impact planning and 2018 compliance/reporting decisions. For domestic partnerships and limited liability companies (LLCs) with minority U.S. partners, including private equity...