and Brian O'Connor
presented "Gain on Sales of U.S. Partnership Interests by Foreign Partners: New Sections 864(c)(8) and 1446(f): Determining and Reporting Gain on Effectively-Connected U.S. Source Income." This CLE/CPE webinar provides tax counsel and advisers with a critical look at sales of U.S. partnership interests by foreign partners under current tax law. The panel discussed new and significant changes to international taxation relating to the disposition of U.S. partnership interests owned by foreign partners and taxpayers, recognized taxable gain, and available planning techniques.