Tax Expert Provides Insight Into Recent U.S. Tax Court Decision on Taxation of Foreign Investments in U.S. Partnerships

The U.S. Tax Court’s recent decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner of Internal Revenue departed from a longstanding Internal Revenue Service (IRS) revenue ruling that made sales of U.S. partnership interests by foreign partners subject to tax in the U.S. See “U.S. Tax Court Ruling May Lead to Increased After-Tax Returns for Foreign Investors That Invest in U.S. Partnerships” (Aug. 3, 2017). A recent webinar offered a primer on U.S. taxation of foreign investors, an analysis of the IRS revenue ruling, an overview of the Tax Court’s reasoning in the Grecian Magnesite decision and its implications. The program was sponsored by The Financial Executives Alliance, a national affinity group administered by First Republic Bank, and featured Pepper Hamilton partner Steven D. Bortnick. This article highlights the principal points from the presentation. For further commentary from Bortnick, see “Tax Proposals and Tax Reforms May Affect Rates and Impose Liabilities on Hedge Fund Managers” (Apr. 16, 2015).

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