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Tax Court Declines to Follow Rev. Rul. 91-32 – Important Development for Foreign Investors!
On July 13, 2017, the U.S. Tax Court (Tax Court) issued a 55-page opinion rejecting the long-standing position of the Internal Revenue Service (IRS) as outlined in Revenue Ruling 91-321 concerning the sale by a foreign person of an interest in a partnership that is engaged in a U.S. trade or business for U.S. federal […]