Proposed regulations under section 864(c)(8) (text of regulations)

The U.S. Treasury Department and IRS today released a version of proposed regulations (REG-113604-18) as guidance under section 864(c)(8) concerning sales of U.S. trade or business partnership interests—measures enacted by the new U.S. tax law (Pub. L. No. 115-97, date of enactment December 22, 2017)—the law that is at times referred to as the “Tax Cuts and Jobs Act” (TCJA).

Read the proposed regulations [PDF 150 KB] (36 pages). These proposed regulations refer to the Grecian Magnesite Mining case.

A statement on this version of the proposed regulations provides that these have been submitted to the Federal Register for publication and are currently pending placement and publication in the Federal Register. "The version of the proposed rule released today may vary slightly from the published document if minor editorial changes are made during the [Federal Register] review process. The document published in the Federal Register will be the official document."

The purpose of this report is to provide text of the regulations. Initial impressions about these proposed regulations will be provided by TaxNewsFlash.

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