![]() ![]() 91-32, which effectively treated gain on the sale of a partnership interest by a foreign partner as the sale of the partner’s interest in partnership assets in determining that the gain was effectively connected with the U.S. In Grecian Magnesite, the tax court rejected the aggregate approach of the Internal Revenue Service (IRS) in Rev. partnerships in their operating structures have taken a keen interest in the ruling. The answer to that question, of course, is “it depends.” Several of our clients in the technology industry with foreign-owned U.S. The recent decision in Grecian Magnesite revives a longstanding debate within the tax community over whether a partnership should be treated as an aggregate or an entity for tax purposes. Structured Finance & Capital Equipment Valuation Portfolio Company Performance Improvement Merger, Acquisition & Divestiture Services ![]()
0 Comments
Leave a Reply. |
Details
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |