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....

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