Nov 4, 2005

Comments Concerning Proposed Regulations Under Section 1446

The American Bar Association’s Section of Taxation published comments co-authored by Michael Karlin in response to the Department of Treasury’s request for comments on proposed and temporary regulations published in conjunction with final regulations under IRC Section 1446. Throughout the comments, Michael highlights concerns about potential overwithholding under Section 1446 in current form and offers suggestions to lessen the burden on foreign partners and U.S. partnerships.

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