Kristen Hazel, Sandra McGill and Susan O’Banion wrote this bylined article on a US Tax Court ruling that a gain realized by a foreign taxpayer on the sale of an interest in a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax. Taxpayers who followed a previous IRS ruling on the issue “might consider whether to file an amended return following the Tax Court’s guidance,” the authors wrote.