The Resource Foreign corporation not taxable on redemption of partnership interest : Tax Court rejects Rev. Rul. 91-32

Foreign corporation not taxable on redemption of partnership interest : Tax Court rejects Rev. Rul. 91-32

Label
Foreign corporation not taxable on redemption of partnership interest : Tax Court rejects Rev. Rul. 91-32
Title
Foreign corporation not taxable on redemption of partnership interest : Tax Court rejects Rev. Rul. 91-32
Creator
Subject
Language
eng
Summary
In Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, the Tax Court held that the capital gain recognized by the taxpayer, a Greek corporation, upon the redemption of its interest in a U.S. limited liability company classified as a partnership, is not taxable, because such gain is not effectively connected with the conduct of a trade or business in the United States (effectively connected income). In so holding, the Tax Court rejected Rev. Rul. 91-32, 1991-1 C.B. 107 , which holds otherwise on similar facts. the authors discuss the case
Citation source
In: Tax management international journal. - Arlington. - Vol. 46 (2017), no. 8 ; 10 p
http://library.link/vocab/creatorName
  • Miller, M.J
  • Brody, E.S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • case law
  • foreign company
  • source of income
  • effectively connected income
  • capital gains tax
Label
Foreign corporation not taxable on redemption of partnership interest : Tax Court rejects Rev. Rul. 91-32
Instantiates
Publication
Label
Foreign corporation not taxable on redemption of partnership interest : Tax Court rejects Rev. Rul. 91-32
Publication

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