Grecian Magnesite Mining, Industrial, & Shipping Co. v. Commissioner, No. 17-1268 (D.C. Cir. 2019): Foreign Corporation’s Disposition of US Partnership Interest Not US Source Income

In Grecian Magnesite Mining, Industrial, & Shipping Co. v. Commissioner, No. 17-1268 (D.C. Cir. 2019), the Court of Appeals for the District of Columbia Circuit has affirmed a Tax Court ruling that a foreign corporation’s proceeds from the redemption of an interest in a U.S. limited liability company that was treated as a partnership was not U.S. source income and was not effectively connected with a U.S. trade or business.

Download full opinion by clicking Grecian Magnesite Mining, Industrial, & Shipping Co. v. Commissioner, No. 17-1268 (D.C. Cir. 2019).

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal..