By Michele Alexander and Ryan Davis ( March 22, 2018, 12:37 PM EDT) -- While much has been made about international tax reform contained in the Tax Cuts and Jobs Act, P.L. 115-97, that modifies the taxation of U.S. taxpayers with multinational holdings and operations, the new law did not leave inbound investment untouched. Notably, the TCJA codified a published ruling in a fairly controversial area of partnership tax law, in a potential disappointment to non-U.S. investors in domestic partnerships and practitioners who questioned the authority for issuing the ruling in the first place....
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