Tag Archives: IRS

Welcome News for Non-U.S. Persons Investing into U.S. Businesses: U.S. Tax Court Rejects Long-Standing IRS Ruling

On July 13, 2017, the U.S. Tax Court, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner,1 rejected the long-standing Internal Revenue Service (IRS) position that a non-U.S. person is taxed on the sale of an interest in an entity that is a “partnership” for U.S. federal income tax purposes (hereinafter, a partnership) … Continue Reading
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