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Partnership Tax Traps and Recent Guidance

Volume 3 No 2   |   Read Article

By Philip R. Hirschfeld

At the end of 2015, the I.R.S. issued a notice designed to limit the instances in which contributions of property to foreign partnerships benefit from nonrecognition of gain. In January, the I.R.S. came under pressure to modify its announced position in final regulations that are currently being developed. Philip R. Hirschfeld explains. See more →