Jim Fuller and David Forst examine the New York State Bar Association's latest analysis of the base erosion and anti-abuse tax (BEAT), which was introduced in the US tax reform.
The 2017 Tax Act added new Section 864(c)(8) on the sale of a partnership interest. The provisions introduce rules that were disputed in Grecian Magnesite v Commissioner.
The Tax Cuts and Jobs Act (2017 Act) overturned Grecian Magnesite v Commissioner, which held that the sale by a foreign person of its interest in a partnership engaged in a US trade or business was not subject to US tax.
