Eversheds Sutherland Tax Reform Law Blog
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OIRA Receives Foreign Partner Sales Regulations

On December 4th the Office of Information and Regulatory Affairs (OIRA) received regulations pertaining to the treatment of foreign partners’ gains on the sale of a U.S. partnership.  The regulations will provide guidance on section 864(c)(8), enacted by the Tax Cuts and Jobs Act, which treats gain from the sale of an interest in a partnership engaged in the conduct of a U.S. trade or...