IRS Floats Rules On Share Sales By Foreign Partners

Law360 (December 20, 2018, 12:30 PM EST) -- The U.S. Department of Treasury on Thursday proposed rules to treat income from the sale of a foreigner's interest in a U.S. partnership as taxable U.S.-sourced income, counter to a U.S. Tax Court decision that mandated the opposite result.

The U.S. Department of Treasury's ruling on income from a foreigner selling his interest in a U.S. partnership contradicted a 2017 U.S. Tax Court decision. (AP) Section 864(c)(8) of the Tax Cuts and Jobs Act effectively re-establishes that the sale of a foreigner's interest in a partnership owning U.S. trade or business assets is effectively connected income, a portion of which is taxable by...

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