"Gain on Sales of U.S. Partnership Interests by Foreign Partners After Grecian Magnesite v. Commissioner," Strafford Publications Webinars and Teleconferences

Brian O’Connor and Friedemann Thomma presented “Gain on Sales of U.S. Partnership Interests by Foreign Partners” on October 3, 2017.

This CLE webinar provided tax counsel and advisers with a critical first look at the landmark Tax Court holding in Grecian Magnesite Mining v. Commissionerthat certain gain realized by a foreign partner on the disposition of a U.S. partnership interest was neither U.S.-sourced nor effectively connected income (ECI) and thus was not taxable. The panel discussed the importance of Grecian Magnesite to foreign partners who own U.S. partnership interests, and to taxpayers who recognized taxable gain on prior dispositions.