Peter Kulick

Peter Kulick

Dickinson Wright

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U.S Tax Court Bounces Rev. Rul. 91-32: Sales of Partnership Interests by Foreign Partners May Not be Subject to U.S. Tax

The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more

7/27/2017  /  Capital Gains , FDAP , Internal Revenue Code (IRC) , IRS , Limited Liability Company (LLC) , Non-Resident Income Taxes , Partnership Interests , Partnerships , Tax Liability

U.S. Tax Court Bounces Rev. Rul. 91-32: Sales of Partnership Interests by Foreign Partners May Not be Subject to U.S. Tax

The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more

7/26/2017  /  Internal Revenue Code (IRC) , IRS , Limited Liability Company (LLC) , Partnership Interests , Partnerships , Tax Liability , Transfer of Interest
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