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 from 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
Ryan J. Coyle
Counsel
McDermott Will & Emery
Mr. Coyle focuses his practice on international tax matters, with an emphasis on providing tax-efficient restructuring... | Read More
Mr. Coyle focuses his practice on international tax matters, with an emphasis on providing tax-efficient restructuring solutions for high-net-worth international families and their closely held businesses. In addition to advising US-based families on income, gift, and estate tax matters, he assists non-US families with tax matters relating to pre-immigration planning and inbound investment.
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Gregory M. Weigand
Partner
McDermott Will & Emery
Mr. Weigand focuses his practice on complex domestic and international tax matters for multinational companies, closely... | Read More
Mr. Weigand focuses his practice on complex domestic and international tax matters for multinational companies, closely held businesses, investment funds and family offices and high-net-wealth individuals. He advises US and foreign-based publicly traded and privately held companies on domestic and international mergers and acquisitions, financing transactions, and global restructuring transactions. Mr. Weigand regularly advises on the tax aspects of complex domestic and international transactions and the formation, structuring, and operation of private equity funds and family offices. He is experienced in negotiating, drafting and documenting transactions involving corporations, partnerships and cross-border entities. In addition, Mr. Weigand regularly represents international businesses and individuals with structuring and reorganizing their US operations and investments, including a significant amount of US real estate-based transactions such as the purchase and sale of commercial real estate and hospitality-related assets.
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