Gain Realized By Non-Resident Foreign Partner Upon The Sale Of Its...
(WorldNews Greece)

In Grecian Magnesite Mining, Industrial & Shipping Co., SA, v. Commissioner of Internal Revenue , the United States Tax Court overturned Revenue Ruling 91-32 and held that gain recognized by a non-resident foreign partner of a U.S. limited liability company upon the sale of its interest was not U.S.-source income, except for the portion attributable to its interest in the company`s real property. ......