Decision could open planning opportunities for non-US partners regarding sale of a partnership interest.
The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided July 13, 2017 — may significantly change how non-US investors invest in US businesses that are in partnership or other pass-through form. The Tax Court held that a non-US person’s capital gain from the sale of its interest in a partnership engaged in a US trade or business generally is not subject to US federal income tax, except to the extent attributable to the non-US person’s share of the partnership’s US real property interests.
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