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Grecian Magnesite Mining

Hold Up, Partner: Proposed Regulations Address Withholding on Foreign Partner Dispositions

June 17, 2019 By Edward Tanenbaum and Heather Ripley

Newly proposed regulations expand withholding on foreign partners transferring interests in partnerships who do business in the United States. Our International Tax Group evaluates the tightening reins on exceptions. Notice 2018-29 and other prior Section 1446(f) guidance Modified withholding exceptions in the new regulations Activation of previously suspended PTP and secondary withholding Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory, Tax Reform Tagged With: 1446(f), ECI, effectively connected income, Grecian Magnesite Mining, IRS, qualified notice, section 1146, Section 1446(f), section 864(c)(8), Sectopm 864, Tax Cuts and Jobs Act, tax reform, TCJA, Treasury, withholdings

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. [...]Read more

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

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