Amendments to Final Regulations for Withholding on Transfers of Certain Partnership Interests: U.S. Internal Revenue Code Section 1446
As communicated in Straight Talk on December 1, 2020, the U.S. Treasury Department (Treasury) and the U.S. Internal Revenue Service (IRS) released final regulations under U.S. Internal Revenue Code (IRC) Section 1446(f) with respect to the withholding tax on a transfer by a non-U.S. person of an interest in a partnership that carries on a trade or business in the U.S. or otherwise realizes income effectively connected with such a trade or business (ECI).
Recently, in Notice 2021-51, the U.S. Treasury Department and the IRS announced that they intend to amend certain regulations under sections 1446(a) and 1446(f) to defer the applicability date to January 1, 2023, for certain provisions relating to the following: (i) withholding under section 1446(f) on transfers of interests in publicly traded partnerships (“PTP interests”); (ii) withholding under section 1446(a) on distributions made with respect to PTP interests; and (iii) withholding under section 1446(f)(4) by partnerships on distributions to transferees.
For more information, read the article.
Bank of Canada Designates Lynx as a Systemically Important Payment System
According to a recent news release, Bank of Canada (BoC) Governor Tiff Macklem has designated Lynx as a systemically important payment system under the Payment Clearing and Settlement Act. The BoC states that this designation brings Lynx under formal Bank oversight.
As part of Canada’s payments modernization efforts, Lynx replaced the Large Value Transfer System (LVTS) as of September 2021. Furthermore, the BoC notes that Lynx inherits the operational functions to reinforce the BoC’s policy interest rate, provides a means for settling obligations from other financial market infrastructures, and channels liquidity from the Bank to financial institutions in times of crisis.
For more information, BoC’s news release.
Financial Services Regulatory Authority of Ontario Releases Latest Newsletter
The Financial Services Regulatory Authority of Ontario (FSRA) has released its latest newsletter that includes a list of key initiatives from August 2021. The FSRA notes that it welcomes feedback on its summary of initiatives and relevant communications.
For more information, read the FSRA’s newsletter.