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Foreign Corporations Capital Gains Internal Revenue Code (IRC)

Freeman Law

The Source of Income from the Sale of Personal Property

Freeman Law on

The Source of Income from the Sale of Personal Property Generally, income from the sale of personal property is “sourced” to the residence of the seller. If the seller is a U.S. tax resident the source of the income is deemed...more

Nutter McClennen & Fish LLP

Treasury Issues Final Regulations on Section 721(c) Partnerships

As you probably know, a taxpayer realizes gain when the taxpayer transfers appreciated property in exchange for other property. There are exceptions to this general rule. One of those exceptions is defined in Internal Revenue...more

Morrison & Foerster LLP

IRS Issues Notice Announcing Intention to Require Gain Recognition on Certain Transfers of Property to Partnerships with Related...

I. Overview - On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more

McDermott Will & Emery

Treasury Releases Guidance for Contributions of Appreciated Property to Partnerships with Related Foreign Partners

McDermott Will & Emery on

On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more

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