31
Aug
Foreign investors in US partnerships had reason to celebrate last month when a major tax court decision rejected the controversial Revenue Ruling 91-32, which stipulates that gains of a non-US partner from the disposition of an interest in a partnership engaged in US trade or business is treated as a sale of partnership assets and subject to US income tax.
In Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, the court ruled that treating the gains as “ECI” (income effectively...