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Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

No Gifts in Proposed Partnership Audit Regulations

New partnership audit and collection regime rules will soon go into effect, defining who can elect out and enabling the Internal Revenue Service to assess taxes directly against the partnerships it audits. Originally...more

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