Final 367 regulations govern the treatment of section 355 distributions by U.S. corporations to foreign persons

Article Abstract:

The author discusses tax issues under IRC section 355 regarding distributions of a US corporation's subsidiary's stock to foreign stockholders, a US corporation's liquidation into a foreign parent corporation, or a foreign corporation's liquidation into a foreign parent corporation.

Stocks, Distribution, Liquidation

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International aspects of the 'check the box' partnership classification procedure

Article Abstract:

The author discusses IRS notice 95-14 regarding 'check the box partnership classification' procedures as it applies to foreign entities.

Partnership, Partnerships

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Form 5471 revisions

Article Abstract:

The author discusses IRS announcement 95-55 regarding changes to Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations and instructions for schedules J, M, N, and O.

Information returns

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