Gain on Sales of U.S. Partnership Interests by Foreign Partners: Sections 864(c)(8) and 1446(f)
Determining and Reporting Gain on Effectively-Connected U.S. Source Income
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers with a critical look at sales of U.S. partnership interests by foreign partners under current tax law. The panel will discuss new and significant changes to international taxation relating to the disposition of U.S. partnership interests owned by foreign partners and taxpayers, recognized taxable gain, and available planning techniques.
Outline
- Determining ECI under current tax law
- Section 1446(f); calculating the amount realized on the disposition of a partnership interest
- Remedial actions and tactics for non-U.S. partners paying tax on partnership sale gain
- Impact on existing partnership structures
Benefits
The panel will review these and other critical issues:
- What actions should counsel recommend to a non-U.S. partner selling a U.S. partnership based on an ECI determination?
- What is the impact of the tax rules on domestic and foreign blocker corporations investing in U.S. partnerships?
- What are the methods of determining the source and calculating ECI of partnership sale gain amounts?
- What should tax counsel consider for existing partnership structures under current tax law?
Faculty
Patrick J. McCormick, J.D., LL.M.
Partner
Rimon Law
Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has... | Read More
Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.
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William R. Skinner
Partner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.
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