By Daniel Nelson, Richard Zarin, Gabriel Quihuis and Sarah-Jane Morin ( January 30, 2018, 5:11 PM EST) -- On Dec. 22, 2017, U.S. President Donald Trump signed into law the Tax Cuts and Jobs Act, P.L. 115-97, and with it sweeping tax reform. The new legislation includes a provision that reverses the U.S. Tax Court's Grecian Magnesite Mining decision[1] and introduces a new 10 percent withholding tax on the sale of certain partnership interests. This new provision has significant implications for buyers and sellers of interests in investment fund vehicles classified as partnerships for U.S. federal income tax purposes and the funds themselves. The new provision will also have significant implications for mergers and acquisitions transactions involving partnerships....
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