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Can Foreign Partners Now Exit Partnerships Tax Free?

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

New Partnership Tax Guidance on Disguised Sales and Liability Allocations

On October 5, 2016, the Treasury Department and Internal Revenue Service (“IRS”) published much-anticipated final, temporary and new proposed regulations providing guidance under Internal Revenue Code sections 707 and 752 on...more

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