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Video instructions and help with filling out and completing Will Form 4797 Partnerships

Instructions and Help about Will Form 4797 Partnerships

Music welcome back to our video series on the US tax reform today we would like to have a focus on the sale of partnership interests Anisa we talked in previous videos about the taxation of pass-through entities but what happens now if I decide I want to sell my interest in the partnership well the short answer is is taxable in the US not an answer I guess people want to hear better not yeah how we get there though is a little interesting maybe for some and basically we end up right where we started so under our internal law and the treaty it's always been clear that with respect to the sale of real property located in the US so the sale of that property whether it was held directly or indirectly through a partnership was always such attacks in the US and exempt with progression in Germany in addition we always had us withholding that was applied under our foreign investment in the real property tax act what we like to refer to as FERC done another nice acronym for us and that's true with respect to real property interest and that has not changed but regarding the sale of a US partnership interest is not a real property interest and that is actually taken you know gone a full-circle really so the IRS has always taken the position that this should be taxable in the US and then we had a case not that long ago that actually held that it was not going to be taxable in the US and now under the new law they've come all the way back around to the IRS s position and has said this is definitely going to be taxable in the US so we thought for...

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