Tax nothings
Article Abstract:
Tax nothings which IRS check-the-box regulations expressly allow to be treated as sole proprietorships, branches, or divisions present many planning and efficiency benefits. Single-member limited liability companies can elect to be disregarded and obtain a US tax result which under prior law often could be reached but not without incurring unnecessary transaction costs. Tax nothings are useful for legitimate business purposes and their abuse should not lead the IRS to limit their availability to all persons.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
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APTs relatively unscathed under new rules
Article Abstract:
Changes in the Taxpayer Relief Act of 1997 and the Small Business Job Protection Act of 1996 have impacted asset protection trusts (APTs). Most APTs are grantor trusts and amended IRC subsection 684(b) allows for nonrecognition of gain on transfers of appreciated property to grantor trusts. A problematic change in the new law is the overbroad definition of trusts subject to the foreign trust reporting requirement.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
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