The authors analyze the regulations proposed in September 2003 and offer suggestions for making the Service's approach more workable.Proposed regulations issued in September 2003 provide rules for the implementation of Section 1446's requirement that a partnership pay to the IRS taxes on behalf...

During the course of the 1990s, a succession of lawyers at the office of Associate Chief Counsel (International) of the Internal Revenue Service led a wise and ultimately successful effort to modernize the regulations under § § 1441 and 1442, dealing with the withholding of tax on investment...

Until the advent of § 1446, 1446's main claim to fame may have been that it was the year that Blarney Castle in its current incarnation was built in Cork, Ireland. There seems to be a mystical connection here. Certainly, the interminable § 1446 regulations, and especially the ponderous...

Section 1446 requires the withholding of tax by partnerships with foreign partners where the partnership has income or gain that is effectively connected with a trade or business carried on by the partnership within the United States (ECI). The final Regulations implement this simple-sounding...

Better late than never, sort of. On May 13, 2005, the IRS issued over 200 pages of final, Temporary, and Proposed Regulations under Section 1446, which was enacted in its current form in 1988. This two-part article reviews the Regulations and offers some comments on the future of this tangled...

Foreign persons buy homes in the United States for a variety of reasons - for personal use during temporary or indefinite stays that may be long-term, such as a job posting in the United States, or short-term, such as a vacation. The U.S. home may be one of several homes they live in during the...

The basic framework and purpose of the tax provisions of a Credit Agreement are the foci of this article. In particular, the article discusses a lender's concerns in negotiating the tax provisions of a Credit Agreement

On January 26, 1993, the United States and Israel signed a protocol to the income tax convention between the two countries which had been signed on November 20, 1975 (the "Proposed Treaty"). Although the Proposed Treaty had been amended by an earlier protocol signed on May 30, 1980 (the "First...