Selected US Tax Developments: The Unbearable Absurdity of the US Tax Rules for Withholding on Dispositions of Partnership Interests
Bibliographic record
Abstract
Section 1446(f) of the Internal Revenue Code requires the transferee of a partnership interest to withhold 10 percent of the amount realized by the transferor if, among other requirements, the transferor is a non-US person, a gain is recognized on the sale, and such gain is "effectively connected" with a US trade or business conducted by the partnership. The author of this article has examined the proposed regulations and other guidance implementing this provision and found them deficient in several respects. He points out that, unfortunately, they disregard the statutory requirements and generally require withholding by all transferees of partnership interests, anywhere in the world, even if the partnership has never conducted any activities within the United States. The proposed regulations and other guidance provide for limited exceptions, but as the author explains, the exceptions are unrealistic and wholly inadequate.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.003 | 0.007 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.002 | 0.003 |
| Science and technology studies | 0.005 | 0.002 |
| Scholarly communication | 0.006 | 0.001 |
| Open science | 0.001 | 0.001 |
| Research integrity | 0.003 | 0.004 |
| Insufficient payload (model declined to judge) | 0.003 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".