Americas

Argentina, Brazil agree on key tax treaty changes

Francisco Lisboa Moreira of Castro Barros, São Paulo, and Sandra Diaz of BaseFirma, Buenos Aires, discuss key changes to the Brazil-Argentina tax treaty, agreed to July 21, noting that taxpayers from both countries may need to evaluate this new arrangement . . .

Americas

US Tax Court decision has big implications for non-US partners in US partnerships

Monte A. Jackel, Senior Counsel at Akin, Gump, Strauss, Hauer & Feld, discusses the implications of the US Tax Court’s July 13 decision in Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, where the Court rejected the IRS’s aggregate approach for taxing a foreign partner’s gain on the redemption of its US partnership interest and concluded that the foreign investor was not subject to US taxation . . .