Uncle Sam Meets Uncle Scrooge - The Temporary Regulations on Foreign Partner Withholding (Part 2)

Michael Karlin was published in the Journal of International Taxation with an article entitled, “Uncle Sam Meets Uncle Scrooge - The Temporary Regulations on Foreign Partner Withholding (Part 2)." Michael discusses the regulatory complexities surrounding Section 1446 of the Internal Revenue Code, which mandates tax withholding by partnerships with foreign partners. In the article, he highlights the need for substantial improvements to this law to ensure fairness and avoid undue withholding burdens on foreign partners and U.S. partnerships.