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Rivkin Radler LLP

The Closely Held Business and The Tax Gap

Rivkin Radler LLP on

Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...more

Cole Schotz

Tax Court Holds That Foreign Corporation’s Sale Of A Partnership Interest Not Taxable In US

Cole Schotz on

The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more

Locke Lord LLP

Recent U.S. Tax Court Case Reverses Long Held IRS Position Regarding Taxation of Sales of Partnership Interests by Foreign...

Locke Lord LLP on

Following the inauguration of the new administration in January 2017, many investors were anticipating the passage of a transformative tax reform bill at some point in 2017. Although legislative tax reform is seemingly...more

Pillsbury Winthrop Shaw Pittman LLP

Grecian: Tax Court Rejects IRS Ruling - Five Things You Need to Know

Pillsbury Winthrop Shaw Pittman LLP on

On July 13, 2017, in Grecian Magnesite Mining, Industrial and Shipping Co. SA v. Commissioner (149 T.C. No. 3 (2017), the U.S. Tax Court concluded that gain recognized by a foreign corporation upon redemption of its interest...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

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