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Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest

By Susan E. O’Banion, Sandra P. McGill & Kristen E. Hazel on August 16, 2017
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In a long-awaited decision, the US Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to follow Revenue Ruling 91-32. The government has yet to comment regarding its intentions to appeal.

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Photo of Susan E. O’Banion Susan E. O’Banion

Susan E. O’Banion focuses her practice on tax matters.

Susan previously worked at a Big Four accounting firm, where she focused on international tax. While in law school, Susan served as comment editor for the Journal of Criminal Law and Criminology. Read …

Susan E. O’Banion focuses her practice on tax matters.

Susan previously worked at a Big Four accounting firm, where she focused on international tax. While in law school, Susan served as comment editor for the Journal of Criminal Law and Criminology. Read Susan O’Banion’s full bio. 

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Photo of Sandra P. McGill Sandra P. McGill

Sandra McGill focuses her practice on international tax planning. Sandra works with US and non-US multinational companies, public and private as well as high net worth individuals and family businesses. Sandra has extensive experience advising clients on a broad range of cross-border tax…

Sandra McGill focuses her practice on international tax planning. Sandra works with US and non-US multinational companies, public and private as well as high net worth individuals and family businesses. Sandra has extensive experience advising clients on a broad range of cross-border tax issues. Read Sandra McGill’s full bio.

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Photo of Kristen E. Hazel Kristen E. Hazel

Kristen E. Hazel has extensive experience representing clients in US and international aspects of federal tax matters, including international acquisitions and divestitures, international joint ventures, and capital plan design and implementation. Her work includes both inbound and outbound transactions. Kristen is the co-chair…

Kristen E. Hazel has extensive experience representing clients in US and international aspects of federal tax matters, including international acquisitions and divestitures, international joint ventures, and capital plan design and implementation. Her work includes both inbound and outbound transactions. Kristen is the co-chair of the Firm’s Captive Insurance Affinity Group. She regularly counsels clients with respect to the tax aspects of organizing, operating and defending captive insurance companies. Read Kristen Hazel’s full bio.

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  • Posted in:
    Tax
  • Blog:
    Tax Controversy 360
  • Organization:
    McDermott Will & Emery
  • Article: View Original Source

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