News & Analysis as of

Non-Resident Aliens Capital Gains

Rivkin Radler LLP

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

Rivkin Radler LLP on

There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

Fox Rothschild LLP

Partnership Interest Sale Inventory Gain is Not U.S. Source Income

Fox Rothschild LLP on

On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner on the sale of her interest in a U.S....more

Rivkin Radler LLP

Increased Capital Gain Rate, Nonresident Aliens, And ESBTs

Rivkin Radler LLP on

Compare and Contrast- Have you spoken to anybody about the infrastructure bill on which the Senate is about to vote? I know I haven’t, except to explain that Speaker Pelosi has stated the House will not consider the bill...more

Akin Gump Strauss Hauer & Feld LLP

Capital Gains Tax on U.K. Property for Non-Residents

According to various reports, the Chancellor of the Exchequer is considering announcing in his Autumn Statement in December that capital gains tax (“CGT”) will be imposed on non-U.K. resident property sellers for the first...more

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