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May 1, 2021

Gain or Loss of Foreign Persons from Sale or Exchange of Partnership Interests

Michael Karlin co-authored an article with Professor Alan Appel in the Journal of International Taxation (Thomson Reuters) entitled "Gain or Loss of Foreign Persons from Sale or Exchange of Partnership Interests," examining Internal Revenue Code sections 864(c)(8) and 1446(f) and recently published Treasury Regulations. The article is available below.

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