IRS issues Notice of proposed rulemaking

On 7 June 2019, the U.S. Internal Revenue Service (“IRS”) issued a Notice of proposed rulemaking with regard to the exception from taxation with respect to gain or loss of a qualified foreign pension fund attributable to certain interests in United States real property (Link). The proposed regulations affect certain holders of certain interests in United States real property and withholding agents that are required to withhold tax on certain dispositions of, and distributions with respect to, such property.

Written or electronic comments and requests for a public hearing must be received by 5 September 2019.

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