The US IRS today released proposed regulations (REG-109826-17) on the section 897(l) exception from section 897(a) gain or loss for qualified foreign pension fund attributable for dispositions of United States real property.
The proposed regulations contain rules relating to the qualification for the exemption under section 897(l), and rules relating to withholding requirements under sections 1445 and 1446 for dispositions of United States real property interests by foreign pension funds and their subsidiaries.
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