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recian Magnesite Mining v. Commissioner

Another Chapter in the Effectively Connected Income Saga—IRS Issues Proposed Regulations on Sales of Partnership Interests by Foreign Partners

January 16, 2019 By Edward Tanenbaum, Daniel Reach and Seth Buchwald

The IRS gets granular on new Section 864(c)(8), created by the Tax Cuts and Jobs Act. Our International Tax Group examines the implications of the newest proposed regulations brought on by tax reform. How Section 864(c)(8) codifies longstanding IRS principles on effectively connected income The proposed regulations’ complex formula for deemed partnership asset sales Application to tiered partnerships and treaties Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: ECI, IRS, recian Magnesite Mining v. Commissioner, Section 1446(f), section 864(c)(8), Section 897(g), Tax Court, Tax Cuts and Jobs Act, tax reform, TCJA

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