Tax guidance on foreign partnership interest sales, interest expense limits, and deemed repatriation tax

Tax guidance on foreign partnership interest sales, interest expense limits, and deemed repatriation tax The passage outlines technical tax rules and withholding requirements for foreign investors and partnership transactions. It contains no specific names, transactions, or allegations involving high‑profile individuals or entities, limiting its investigative value. While it could be a useful background for tracing financial flows in future investigations, it offers no concrete leads. Key insights: Foreign partner gains on partnership interest sales may be treated as US effectively connected income, triggering 10% withholding.; New withholding obligations apply to purchases of partnership interests after Dec 31 2017.; Business interest expense deductions are limited to 30% of adjusted taxable income (20% after 2022).