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Partnerships › Foreign Partner › Limited Liability Company (LLC)

Mayer Brown

New Version of US Internal Revenue Service Form W-9 Requires Partnership Look-Through

Mayer Brown on

In March 2024, the Internal Revenue Service (“IRS”) released a new revision to Form W-9. Forms W-9 previously provided or collected do not expire nor need to be refreshed due to the publication of the new revision....more

Hogan Lovells

Final regulations - Foreign partner's U.S. tax liability on transfer of partnership interest

Hogan Lovells on

Given the overall development of the secondaries market and the increasing volume and size of secondary funds, the U.S. tax and withholding regime that applies to a foreign partner transferring an interest in a partnership...more

Mintz

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

Mintz on

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

Roetzel & Andress

Gain Realized By Non-Resident Foreign Partner Upon The Sale Of Its Interest In A U.S. Partnership Is Not U.S.-Source Income Unless...

Roetzel & Andress on

In Grecian Magnesite Mining, Industrial & Shipping Co., SA, v. Commissioner of Internal Revenue (filed on July 13, 2017), the United States Tax Court overturned Revenue Ruling 91-32 (which had been relied on since 1991) and...more

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