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

---

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)

---

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

Similar abstracts:

• Abstracts: Switch-hitters saving the day; two corporations looking to settle lawsuits hire plaintiffs lawyers. Putting the squeeze on juries
• Abstracts: Management guide on structuring and implementing reductions in force to comply with federal, state and local laws
• Abstracts: The third and fourth sessions of the UN Preparatory Committee on the Establishment of an International Criminal Court
• Abstracts: Through a lens darkly: proposed "C" reorganization regulations clear up the Bausch & Lomb problem. Form and function in stock acquisitions followed by liquidations and mergers

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