Membership or Partnership Interest Purchase Agreement: No Realized Gain Certification (Section 1446(f)) | Practical Law

Membership or Partnership Interest Purchase Agreement: No Realized Gain Certification (Section 1446(f)) | Practical Law

This Standard Document is delivered by a foreign seller of a non-publicly traded partnership or membership interest to inform the buyer that the seller will not realize gain on the sale and is therefore not subject to withholding under IRC Section 1446(f). If the seller is a foreign individual or entity, the buyer must withhold under IRC Section 1446(f) unless an exception applies. This Standard Document has integrated notes with important explanations and drafting tips.

Membership or Partnership Interest Purchase Agreement: No Realized Gain Certification (Section 1446(f))

by Practical Law Corporate & Securities
Maintained • USA (National/Federal)
This Standard Document is delivered by a foreign seller of a non-publicly traded partnership or membership interest to inform the buyer that the seller will not realize gain on the sale and is therefore not subject to withholding under IRC Section 1446(f). If the seller is a foreign individual or entity, the buyer must withhold under IRC Section 1446(f) unless an exception applies. This Standard Document has integrated notes with important explanations and drafting tips.