Rev. Rul. 91-32 Archives - TAX CONTROVERSY 360

Rev. Rul. 91-32

Read the October Issue of Focus on Tax Strategies & Developments

by Kevin Spencer, Kristen E. Hazel, Robin L. Greenhouse, Sandra P. McGill, Timothy S. Shuman, McDermott Will & Emery, Alejandro Ruiz, David G. Noren and Jean A. Pawlow | Nov 1, 2017 | Court Procedure Matters, IRS Guidance, State Controversy, Tax Reform, Tax Refunds, Transfer Pricing Resource, Trial Courts, Uncategorized

The October 2017 issue of Focus on Tax Strategies & Developments has been published. This issue includes five articles that provide insight into US federal and international tax developments and trends across a range of industries, as well as strategies for navigating these complex issues.

Republican Leaders Release Tax Reform Framework
By David G. Noren Alexander Lee

M&A Tax Aspects of Republican Tax Reform Framework
By Alexander Lee, Alejandro Ruiz and Timothy S. Shuman

State and Local Tax Aspects of Republican Tax Reform Framework
By Peter L. Faber

Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest
Kristen E. Hazel, Sandra P. McGill and Susan O’Banion

The IRS Attacks Taxpayers’ Section 199 (Computer Software) Deductions
Kevin Spencer, Robin L. Greenhouse and Jean A. Pawlow

Read the full issue of Focus on Tax Strategies & Developments.

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

by Kristen E. Hazel and Sandra P. McGill | Aug 16, 2017 | Court Procedure Matters, IRS Audits, IRS Guidance, Tax Refunds, Trial Courts, Uncategorized

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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