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Partnerships › Foreign Partner › Tax Court

Fenwick & West LLP

Rawat Creates a Ripple in Statutory Interpretation Principles

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Recently, in Rawat v. Commissioner, the D.C. Circuit reversed the Tax Court decision and held that a foreign partner would not be subject to U.S. tax on selling an interest in a partnership with “hot assets” subject to §...more

Fox Rothschild LLP

Partnership Interest Sale Inventory Gain is Not U.S. Source Income

Fox Rothschild LLP on

On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner on the sale of her interest in a U.S....more

Kramer Levin Naftalis & Frankel LLP

Funds Talk: September 2017 - Tax Court Declines to Follow Rev. Rul. 91-32

Kramer Levin Naftalis & Frankel LLP on

In a recent decision, Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, the U.S. Tax Court declined to follow Revenue Ruling 91-32, and held that gain on the sale of an interest in an operating...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

Foley & Lardner LLP

U.S. Tax Court Ruling Exempts Gain on Foreign Partner's Sale of a Partnership Interest

Foley & Lardner LLP on

On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more

Bracewell LLP

Can Foreign Partners Now Exit Partnerships Tax Free?

Bracewell LLP on

In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more

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