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Diagram: nonresident sells a partnership interest; section 751 gain changes character only and is sourced to the seller's home state

California Loses Its “Hot Asset” Argument: What a New Ruling Means for Nonresidents Selling a Partnership Interest

A new California ruling sources nonresidents’ gain on a partnership interest sale, including 751 hot-asset gain, to their home state. See who it affects.

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NONRESIDENT ALIENS AND THE § 121 PRINCIPAL RESIDENCE EXCLUSION

Nonresident Aliens and The Section 121 Principal Resident Exclusion

Selling a home in the U.S. as a nonresident alien raises two big questions. First, can you use the Section 121 home sale exclusion? Second, how does FIRPTA withholding apply? This guide answers both. What is the Section 121 exclusion? Internal Revenue Code Section 121 lets you exclude gain from selling your main home. A

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Partnership Special Allocation

Take Advantage of Partnership Special Allocation

One advantage of running a business as a partnership is the right to make special allocations of tax items among the partners. You get the same option if you run your business as an LLC taxed as a partnership. This guide explains how special allocations work and why they matter. What are special allocations? A

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