Reminders

Section 1446(f) final regulations published. T.D. 9926, published on November 30, 2020, available at IRS.gov/IRB/2020-51_IRB#TD-9926, contains final regulations (the section 1446(f) regulations) relating to withholding and reporting required under section 1446(f) (1), including requirements that apply to brokers effecting transfers of publicly traded partnership (PTP) interests and partnership withholding under section 1446(f)(4) (on distributions to a transferee that failed to properly withhold under section 1446(f)(1)). The section 1446(f) regulations also revise certain requirements under section 1446(a) relating to withholding and reporting on distributions made by PTPs.

Applicability date of certain regulations under sec- tion 1446(a) and 1446(f). Notice 2021-51, 2021-36 I.R.B. 361, available at IRS.gov/IRB/ 2021-36_IRB#NOT-2021-51 , announced the intention to amend the regulations under sections 1446(a) and 1446(f) to reflect the applicability date of January 1, 2023, for certain provisions relating to the following.

• Withholding and reporting on transfers of PTP interests.

• The revisions included in the section 1446(f) regulations relating to withholding on PTP distributions under section 1446(a).

• Partnership withholding under section 1446(f)(4) on distributions to a transferee that failed to properly withhold under section 1446(f)(1).