On 21 September 2020, the US Treasury and the IRS finalized regulations under Section 864(c)(8), generally retaining the basic approach and structure of the proposed regulations issued on 20 December 2018 (REG-113604-18).
Author
Leah Gruen
BrowsingLeah Gruen is counsel in the Firm's Global Tax Practice Group in Chicago. She provides tax structuring advice to corporations, partnerships, limited liability companies, REITs and other pass-through entities.