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2.26 MB
Extraction Summary
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People
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Events
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Quotes
Document Information
Type:
Legal/financial memorandum or report
File Size:
2.26 MB
Summary
This document outlines changes introduced by the "Tax Act" (likely the Tax Cuts and Jobs Act of 2017) regarding the taxation of non-US partners and interest expense deductions. It details that gains from selling partnership interests are treated as effectively connected income (ECI) subject to withholding, and establishes a new limitation on business interest deductions capped at 30% of adjusted taxable income.
Organizations (3)
| Name | Type | Context |
|---|---|---|
| IRS | ||
| Tax Court | ||
| Conference Committee |
Timeline (3 events)
Tax Act
Revenue Ruling 91-32
dispositions of partnership interests after December 31, 2017
Relationships (3)
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Key Quotes (3)
"The Tax Act specifically provides that gains realized by a non-US partner on a sale or exchange of a partnership interest will be treated as effectively connected US trade or business income ("ECI")"Source
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Quote #1
"the Tax Act limits the deduction for "net business interest" expense for every type of business, regardless of entity form, to 30 percent of adjusted taxable income."Source
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Quote #2
"A more restrictive 30% of EBIT limitation (net earnings before deducting interest expense and taxes) applies for 2022 and later years."Source
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Quote #3
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