Kissing the Blarney Stone - A Practical Guide to Structuring Partnership Agreements in Light of the 1446 Regulations

Michael Karlin was published in Tax Management Memorandum with an article entitled, “Kissing the Blarney Stone - A Practical Guide to Structuring Partnership Agreements in Light of the 1446 Regulations.” In the article, Michael offers discussion into how to mitigate the harshness of Section 1446, which mandates tax withholding by U.S. partnerships with foreign partners, from the outset in drafting originating partnership agreements.