Michael Karlin co-authored an article for the Journal of International Taxation entitled, “At Long Last... Final Regulations on Foreign Partner Withholding.” The article delves into the complexities of Section 1446 of the Internal Revenue Code, which mandates tax withholding by partnerships with foreign partners. Karlin highlights the inherent flaws and inconsistencies in this legislation, which often result in undue burdens on foreign investors and interfere with business partnerships.
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