Taxation of Foreign Persons Who Dispose of Interests in Partnerships – Article (Volume 15, Chapter 300A) in The Partnership Tax Practice Series 2018, Practicing Law Institute

On March 18, 2018, Michael Karlin published "Taxation of Foreign Persons Who Dispose of Interests in Partnerships," with Bianca Ko and Alan Appel, a professor of law and the director of the International Tax Program at New York Law School. Their article described questions that were raised by the creation of sections 864(c)(8) and 1446(f) of the Internal Revenue Code. In this article, they ask for guidance on their concerns.