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Articles by F. Scott Farmer
Morgan Lewis Practices, Lawyers Recognized by ITR 2025 World Tax Guide
LONDON, August 29, 2024: Morgan Lewis has earned and maintained practice and individual lawyer rankings in the 2025 edition of International Tax Review’s(ITR’s) World Tax guide. Inclusion in this comprehensive guide to the world’s leading tax firms is determined by client feedback, practical evidence, and peer feedback ranking criteria, per ITR.
Final Section 956 Regulations Follow Approach of Proposed Regulations—with Two Helpful Modifications | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
IRS Proposed Regulations Under Internal Revenue Code Section 965 | JD Supra
JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations. This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services").
Tax Reform Legislation Reverses Grecian Magnesite Mining, Adds New Withholding Tax
New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions. On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the Act). Included in the new legislation is a provision that reverses the Grecian Magnesite Mining decision by the US Tax Court[1] and introduces a new 10% withholding tax on the sale of certain partnership interests.
Grecian Magnesite Mining: Impact on Investments by Non-US Investors in US Funds
US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds. On July 13, the US Tax Court issued a taxpayer-favorable decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, [1] concluding that a non-US partner is not subject to US tax on gain from the sale of a partnership interest in a partnership conducting business in the United States.
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