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D.C. Circuit: Foreign partners and effectively connected ...

The case is: Industrial Shipping Co., SA v. Commissioner, No. 17-1268 D.C. Cir. June 11, 2019. Read today’s . decision [PDF 174 KB] from the D.C. Circuit. 2017 tax law references Tax Court’s opinion in legislative history

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    Grecian Magnesite Mining v. Commissioner: Foreign Investor ...

     · Decision. Against this backdrop, the Tax Court considered the case. The taxpayer, GMM, a Greek corporation, was a partner in Premier Magnesia, LLC Premier, a US partnership. Premier was engaged in a US trade or business, and paid US federal income tax on its allocable share of income from Premier’s US …

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  • Proposed regulations under section 864c8 text of ...

    Proposed regulations under section 864c8 text of ...

    These proposed regulations refer to the Grecian Magnesite Mining case. A statement on this version of the proposed regulations provides that these have been submitted to the Federal Register for publication and are currently pending placement and publication in the Federal Register.

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  • GRECIAN MAGNESITE S.A. | LinkedIn

    GRECIAN MAGNESITE S.A. | LinkedIn

    S.A. is a specialist. The company produces and commercializes Caustic Calcined Magnesia, Deadburned Sintered Magnesia, Magnesium Carbonate Raw …

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  • Grecian Magnesite - ellinikifoni.gr

    Grecian Magnesite - ellinikifoni.gr

    is a privately owned company established in 1959 as a and industrial concern. However the expertise of the owners Portolos family goes back to 1914, when J.G. Lambrinides the "eminence grise" of Greek and a pioneer engineer, started the development and exploitation of most of the activities in Greece.

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  • Mining - Grecian Magnesite S.A.

    Mining - Grecian Magnesite S.A.

    at a glance: - OREBODY. MgCO3 White color “lefkolithos”= white stone “Stockwerk type” of orebody – thin veins of within the host rock Waste rock is mainly serpentine and dunite Main characteristics of …

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  • What’s News in Tax

    What’s News in Tax

    The Grecian Magnesite Case. Grecian Magnesite. involved the redemption of a foreign corporation’s interest in a U.S. limited liability company “LLC” that was classified as a partnership for federal tax purposes. The LLC was engaged in the business of mining and extracting magnesite in the United States.

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  • Grecian Magnesite | Bus Ex

    Grecian Magnesite | Bus Ex

    In Chalkidiki, Grecian Magnesite extracts the mineral ore through open-cast mining. Magnesite often contains traces of iron, giving it a grey or brown colour, but because the magnesite deposits in Chalkidiki are unusually pure, their colour is whiteÔÇöand the Greek …

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  • Grecian Magnesite

    Grecian Magnesite

    is a privately owned company established in 1959 as a and industrial concern. However the magnesite expertise of the owners Portolos family goes back to 1914, when J.G. Lambrinides the “eminence grise” of Greek magnesite and a pioneer engineer, started the development and exploitation of most of the magnesite activities in Greece. …

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  • Tax Cuts and Jobs Act Reverses Short Lived Grecian ...

    Tax Cuts and Jobs Act Reverses Short Lived Grecian ...

    as well as the implications of its reversal by the TCJA. Foreign direct investment FDI into the United States was 468.33 trillion dol-lars in 2017.10 The United States has consistently ranked as the worlds top in-vestment destination." Limited liability companies LLCs are popular for. 3 . Id.

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  • U.S. Tax Court Ruling Exempts Gain on Foreign Partners ...

    U.S. Tax Court Ruling Exempts Gain on Foreign Partners ...

     · On July 13, 2017, the U.S. Tax Court issued a decision in , Industrial & Shipping Co., SA v.Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S. pass-through entities.The Tax Court decision rejected a longstanding Internal Revenue Service IRS revenue ruling that held that a non-U.S. investor’s capital …

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  • Tax Court Rules Foreign Partner Not Liable for Tax On ...

    Tax Court Rules Foreign Partner Not Liable for Tax On ...

    On July 13, 2017, the Tax Court held in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Comm’r, 149 T.C. No. 3 2017 that the petitioner, a foreign corporation that disposed of its interest in a partnership that was engaged in a U.S. trade or business, was not liable for tax on certain gain recognized on the disposition.

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  • Tax Reform Legislation Reverses Grecian Magnesite Mining ...

    Tax Reform Legislation Reverses Grecian Magnesite Mining ...

     · Included in the new legislation is a provision that reverses the Grecian Magnesite Mining decision by the US Tax Court and introduces a new 10% withholding tax on …

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  • US Tax Court decision has big implications for non-US ...

    US Tax Court decision has big implications for non-US ...

    . The facts of are fairly straightforward. The taxpayer was a foreign corporation that invested in a US LLC taxed as a partnership for US income tax purposes that was engaged in a trade or business in the United States.

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  • Podcast: Grecian Magnesite Mining v Commissioner of ...

    Podcast: Grecian Magnesite Mining v Commissioner of ...

    Rom, I understand that the petitioner, Grecian Magnesite Mining or GMM was a privately owned Greek corporation that focused on magnesite mining and sales all over the world and also owned a minority interest in a U.S. partnership. Could you tell us more about it? Rom Watson: Sure. As you said, GMM was a Greek corporation, and it operated a worldwide business of mining and selling magnesia and …

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  • Foreign Partner’s Gain on Sale of its Interest in U.S ...

    Foreign Partner’s Gain on Sale of its Interest in U.S ...

     · GMM, a Greek corporation, owned a minority interest in Premier Chemicals, a Delaware LLC classified as a partnership for tax purposes and engaged in activities in the U.S. Other than its interest in Premier, GMM had …

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