A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more
7/19/2017
/ Capital Gains ,
Foreign Investment ,
Foreign-Owned Corporations ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Non-Resident Income Taxes ,
Partnership Interests ,
Partnerships ,
Reversal ,
Tax Court ,
Transfer of Interest
All eyes are on Washington—or should we say Manhattan—these days, searching for clues about where our ship is heading with U.S. President-elect Donald Trump at the helm. Recently, there have been cabinet appointments to...more
1/6/2017
/ Affordable Care Act ,
Capital Gains ,
Clean Water Act ,
Corporate Taxes ,
Deregulation ,
Dodd-Frank ,
Energy Sector ,
Financial Stimulus ,
Foreign Investment ,
Fossil Fuel ,
Infrastructure ,
Initial Public Offering (IPO) ,
Merger Controls ,
National Security ,
Pass-Through Entities ,
Permits ,
Private Equity ,
Repeal ,
Tax Reform ,
Trump Administration ,
Volcker Rule
India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more
The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed into law on December 18, 2015, has resulted in a number of changes to the taxation of investments in U.S. real property by foreign investors. Among...more