i keep all my cuttings under the shade once they are outside. they do get partial sun through out the day. i didn't have any issue last spring.
from what i have read, the leaf will burn if it was grown indoor then exposed to the sun. if the leaf came when it was outside under the sun, it will be more hardened and have less chance of burning up. not sure if this is true or not, but most of my older trees didn't have any issue with burn. my Black Madeira will all go out to full sun coming spring along with few others. if i seen burn on the leaves, i'll move then to partial shade.