United States: IRS Takes View That FIRPTA Exemption For Publicly Traded Stock Must Be Tested At Partnership Level - Akin Gump Strauss Hauer & Feld LLP

In a Chief Counsel Memorandum released May 19, 2023 (the Memorandum), the Internal Revenue Service (IRS) asserted that partnerships must determine the availability of the 5% and 10% ownership thresholds...