Single-member foreign entities

Article Abstract:

The IRS check-the-box business entity classification system has implications for single-member business entities operating in foreign countries. Entities classified one way for US tax purposes may not be recognized in foreign jurisdictions. Additional problems are created by the lack of clear IRS definitional guidance regarding entity membership. Until such guidance is issued, reference to legitimate concepts of ownership may be necessary.

United States, Tax Administration, Small Business, International aspects, Tax administration and procedure, Business enterprises

---

Contract manufacturing: Rev. Rul. 97-48 revokes Rev. Rul. 75-7

Article Abstract:

The IRS incorrectly changed its Revenue Ruling 75-7 position on controlled foreign corporations contract manufacturing relationships with Revenue Ruling 97-48. The ruling is not supported by IRC section 954, regulations under that section, or established judicial authority. Taxpayers will probably not adjust their operations to comply with the ruling because it is obviously erroneous and will not stand judicial or congressional scrutiny.

Contract manufacturing

---

New Code section 367 regulations

Article Abstract:

Stock transfers between US persons and foreign corporations in IRC section 351 and section 354 exchange transactions are the subject of IRS final regulations under section 367 which were issued in June 1998. Recognition of gain on stock transfers to foreign corporations is required unless the transferor controls under 5% of the foreign corporation and agrees to a 5-year recognition of gain agreement.

Tax Law, Laws, regulations and rules, Stocks, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), international

Similar abstracts:

• Abstracts: Cashing in on annuities. The interactive imperative. Payoff deferred
• Abstracts: Sidestep the traps for the best savings deal. Pre-Isa accounts that jump the gun
• Abstracts: Mapping out a sales force strategy: software offerings help companies improve their market presence. Gaining continuity across systems
• Abstracts: Transforming portfolio management. Re-thinking the credit process. The uneasy relationship
• Abstracts: IRS lacks right to tax preparation software and its source code. Three cases dismissed because taxpayers missed deadlines

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.