Gain on Sales of U.S. Partnership Interests by Foreign Partners: New 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 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
- Current tax law and reinstatement of Revenue Ruling 91-32
- Determining ECI under current tax law
- Section 1446(f) and Notice 2018-29; 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 from a sale of a U.S. partnership based on an ECI determination?
- What is the potential impact of the new tax law 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 in light of the new tax law?
Faculty
Brian J. O'Connor
Partner
Venable
Mr. O'Connor co-chairs the firm's Tax and Wealth Planning Group and provides tax advice to partnerships... | Read More
Mr. O'Connor co-chairs the firm's Tax and Wealth Planning Group and provides tax advice to partnerships and to public and closely held businesses and their owners. Before coming to Venable, he worked as attorney-advisor with the IRS Office of Chief Counsel, assigned to projects and guidance involving partnerships and S corporations.
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Friedemann Thomma
Partner
Venable
Mr. Thomma is Chair of the Firm's International Tax Practice. He focuses on corporate international tax planning... | Read More
Mr. Thomma is Chair of the Firm's International Tax Practice. He focuses on corporate international tax planning and U.S. taxation of foreign operations. He has managed large-scale global structuring projects, including the design, implementation, and post-implementation phases, for companies in various industries and jurisdictions. He has also served as the primary contact for multinational corporate clients, working closely with in-house tax, legal, treasury, and accounting departments to implement international legal and tax restructuring projects and post-M&A-integration projects.
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