Abstracts » Law

Partnerships can be restructured to meet changing needs

Article Abstract:

A discussion of the tax benefits resulting from the restructuring of partnerships is the focus of this article which provides the following seven available restructuring methods: liquidating distributions, conversions, divisions, partnership agreement amendments, spin-offs to limited liability companies, use of special allocation limited liability companies, and incorporation.

Tax Management, Partnerships, Analysis, Planning, Tax accounting, Tax planning

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Structuring U.S. operations for foreign corporations in the current tax climate

Article Abstract:

The authors discuss opportunities for foreign corporations with branch or partnership interest in the US under US tax law.

Branches (Business enterprises)

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Income received by entities affected by a U.S. treaty

Article Abstract:

The author outlines rules issued by the IRS on June 30, 2000, on the eligibility of US source income, paid to a domestic or foreign hybrid, for a reduced tax rate pursuant to a treaty. Examples of hybrid entities meeting eligibility requirements for treaty benefits are provided.

International, Interpretation and construction, Tax treaties

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