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Use of partnership in international dealings can be beneficial for both inbound and outbound transactions

Article Abstract:

Partnerships offer numerous advantages in international dealings, such as flow through of losses, limited liability at the entity level, no entity-level tax, special allocations, and the ability to withdraw assets without tax. They also provide various planning opportunities in structuring international ventures. Despite some disadvantages that need to be considered, including subjectivity to IRS hostility in outbound context and several setbacks in the inbound context, they will continue to provide beneficial planning alternatives in international transactions.

Author: Middleton, Charles I.
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1999
Partnerships, Analysis, Partnership

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Taxpayer Cannot Combine Passive and Nonpassive Operations Into a Single Undertaking

Article Abstract:

On the issue of whether the rental operations should be classified as a nonpassive activity for tax purposes, the court held that taxpayer's two rental units cannot be combined into the nonrental operation for passive loss rules.

Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1997
United States, Taxation, Laws, regulations and rules, Lease and rental services industry, Lease and rental services, United States. Internal Revenue Service, Passive activity (Taxation)

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