I posted a month or 2 ago about the new withholding tax regulations on the sales proceeds of US partnerships by foreign persons.  At the time, I though publicly-traded partnerships would continue to be exempt from the withholding tax regime, but that was a mistake.  The only open question is who does the withholding.

 

The withholding is 10% of the total proceeds, with some limited exemptions.  I don't understand the regs' reference to qualified intermediaries and nonqualified intermediaries so I'm not sure who in the chain has to do the 10% withholding.  It seems clear that the MLP doesn't do it, and mostly the responsibility is on the broker (similar to what happens now with the 37% withholding tax on distributions paid to foreign investors.  I am not sure of the effective date - there's a bunch of stuff in there about QI's changing their agreements before 2023, which confuses me.