August 24, 2021
IRS changes applicability date to January 1, 2023, for certain provisions under IRC Section 1446(f) regulations on withholding on transfers of partnership interests
The IRS announced in Notice 2021-51 that it deferred the applicability date of certain withholding provisions under the IRC Section 1446(a) and 1446(f) regulations until January 1, 2023. The IRS will amend the regulations to reflect this new date for withholding under: (1) IRC Section 1446(f), on transfers of interests in publicly traded partnerships (PTPs); (2) IRC Section 1446(a), on distributions made with respect to PTP interests; and (3) IRC Section 1446(f)(4), by partnerships on distributions to transferees. Taxpayers may rely on these modifications immediately. A Tax Alert is forthcoming.