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Sale Of U.S. Operating Partnerships By Non-U.S. Persons May Not Generate ECI—U.S. Tax Court Declines To Follow Revenue Ruling 91-32
In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service ("IRS"), articulated in Revenue Ruling 91-32
United States
10 Aug 2017
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