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Federal & International Tax ADVISORY: Big Tax Court Win for Foreign Investors in U.S. Partnerships

July 24, 2017 By Edward Tanenbaum, Andy Immerman, Stefanie Kavanagh and Scott Harty

Our Federal & International Tax Group examines the long-awaited decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner. While a win for foreign investors in U.S. partnerships, it may not be the final word.

  • Repudiates decades-long position of IRS
  • May have a real impact on U.S. foreign investment
  • May not be the last word on the subject

Read the full advisory here.

Filed Under: Federal Tax Advisory, International Tax Advisory Tagged With: aggregate, Department of Treasury, entity, foreign investor, Grecian Magnesite Mining, INdustrial & Shipping Co., IRS, Obama Administration, Rev. Rul 91-32, SA, Section 741, Treasury, Trump, v. Commissioner

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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About Andy Immerman

Andy Immerman is a member of the Federal & International Income Tax Group. He focuses on federal income tax planning and transactional work for corporations, limited liability companies and partnerships.

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About Stefanie Kavanagh

Stefanie Kavanagh is an associate in the Federal & International Tax Group. She focuses her practice on tax planning and structuring for domestic and international business entities as well as matters relating to real estate investment trusts.

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About Scott Harty

Scott Harty is a partner in the Federal & International Tax Group and focuses his practice on complex domestic and cross-border commercial transactions, including taxable and tax-free mergers and acquisitions, joint ventures, and corporate restructurings.

[Read Bio]

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