This advisory discusses recently released Field Attorney Advice whereby the IRS reaffirmed its position that gain on the sale of a partnership interest by a nonresident alien may be subject to U.S. tax as effectively connected income (ECI). The taxpayer was also liable for annually assessed interest on the deferred tax on the sale under the installment sale rules.
The advisory is provided in PDF on the Alston & Bird website: www.alston.com/advisories/Int-tax-march-2013
