Michael Karlin and Alan Appel of Bryan Cave LLP co-authored an article entitled “Living with the Final Partnership Withholding Regulations,” which was published in the Tax and Accounting Center’s “International Journal.” The comprehensive piece examines how to effectively plan for partnerships with foreign partners around the finalized 2008 version of §1446, which still remains problematic as the good driver certificate provisions are limited and problematic as a remedy for over-withholding, leaving far too many deductions, losses, and credits unacknowledged.
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