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Text of IRS Proposed Regs: Application of Amended Section 897 to Foreign Pension Funds Holding U.S. Real Property
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
June 6, 2019
25 pages. "This document contains proposed regulations regarding the exception from taxation with respect to gain or loss of a qualified foreign pension fund attributable to certain interests in United States real property. The proposed regulations also include rules for certifying that a qualified foreign pension fund is not subject to withholding on certain dispositions of, and distributions with respect to, certain interests in United States real property. The proposed regulations affect certain holders of certain interests in United States real property and withholding agents that are required to withhold tax on certain dispositions of, and distributions with respect to, such property."

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