On October 7th, 2020, the IRS published the final regulations on “Withholding of Tax and Information Reporting with Respect to Interests in Partnerships Engaged in a U.S. Trade or Business". These regulations establish a new withholding and reporting regime for transactions of interests in and distributions by U.S. partnerships. This affects primarily non-U.S. persons, including Austrian qualified intermediaries. The majority of these regulations are applicable as of January 1st, 2022. Qualified intermediaries must integrate the new obligations into their existing systems.
