IRS Floats Tax Exemption Rules For Foreign Pension Funds
Law360 (June 6, 2019, 9:05 PM EDT) -- The Internal Revenue Service issued proposed regulations on Thursday affecting the tax exemption for gains or losses of a foreign pension fund that's tied to certain interests in U.S. real estate.
The rules, which fall under Internal Revenue Code Sections 897, 1445 and 1446, would also set terms for certifying that a qualified foreign pension fund isn't subject to withholding on certain dispositions of, and distributions affecting, certain interests in U.S. real estate.
IRC Section 897 addresses how foreign pension funds qualify for the tax exemption, and Sections 1445 and 1446 pertain to withholding requirements for qualified funds and their affiliates....
Stay ahead of the curve
In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.
Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
Create custom alerts for specific article and case topics and so much more!