Tax treatment; rules for partnerships usually apply; ventures can be structured so as to optimally address several regulatory and control issues
Article Abstract:
The taxation rules for partnerships usually apply to joint ventures unless they are structured as a corporation or a limited liability company electing to be taxed as a corporation. Internal Revenue Code Section 761, as amended in 1986, defines the term partnership, as including joint ventures. There is, as a general rule, no tax liability upon forming a joint venture regardless of whether it elects to be taxed as a corporation or partnership, When appreciated assets are contributed, "carryover" basis taxation rules apply. Other specific tax issues are discussed.
Publication Name: The National Law Journal
Subject: Law
ISSN: 0162-7325
Year: 1998
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IRS issues 'whole hospital' joint-venture ruling; a nonprofit in a venture with a for-profit must retain control in order to remain tax-exempt
Article Abstract:
The IRS's hospital-coordinated examination program focuses on joint ventures between nonprofit and for-profit hospitals, and an action in which the IRS is defending the denial of an IRS 501(c)(3) exemption to a nonprofit corporation in a joint venture with for-profit entities in the operation of an ambulatory surgical center is pending. The IRS has intimated that it would issue a ruling regarding joint ventures between non-profit and for profit-entities involving whole hospitals, partly in response to the Columbia/HCA Healthcare Corp activities.
Publication Name: The National Law Journal
Subject: Law
ISSN: 0162-7325
Year: 1998
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Tax breaks aid employees overseas; companies that send workers abroad need to analyze foreign tax and compensation issues
Article Abstract:
Many financial hardships come with working overseas and two prominent tax advantages of such employment are the foreign earned-income exclusion and the foreign tax credit, companies also offer benefits such as an overship hardship premium, a cost-of-living-allowance, a home-leave allowance and an equalization package. As US businesses expand overseas, the need to send US employees abroad will continue increasing, and the need to evaluate these tax and compensation issues will become more important.
Publication Name: The National Law Journal
Subject: Law
ISSN: 0162-7325
Year: 1998
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