Treatment of hybrid arrangements under Subpart F

Article Abstract:

IRC Notice 98-11 contains rules aimed at business arrangements which are the result of elections under the IRS check-the-box business entity regulations. Those regulations allow greater freedom in structuring business formations and in avoiding IRC Subpart F taxation. Use of hybrid business entities may allow controlled foreign corporations to manipulate passive income for tax reduction purposes. Regulations are anticipated to have broader application than Notice 98-11 which was aimed at some foreign personal holding companies.

Tax Law, Public Finance Activities, International, Tax Evasion & Penalties, Laws, regulations and rules, Business enterprises, Tax penalties, Controlled foreign corporations, Passive activity (Taxation)

---

Benefits of customs planning

Article Abstract:

The author presents information helpful for customs planning in taxation from the Arthur Andersen LLP and Hewlett-Packard Customs Best Practices Symposium.

Management, Planning, International business enterprises, Multinational corporations, Tax planning, International trade, Customs administration

---

Mexico's maquiladora program: the new agreement

Article Abstract:

The author discusses an agreement reached between the US and Mexico in Oct 1999 regarding the maquiladora industry.

Mexico, Offshore assembly industry

Similar abstracts:

• Abstracts: A comparison of a security agreement under the current Article 9 and the new Article 9. A comparison of the current Article 9 and the new Article 9
• Abstracts: Prepayment premiums: a bankruptcy court analysis of reasonableness and liquidated damages. Is a defective mortgage protected from a preference claim?
• Abstracts: The Restatement (Third) of Torts and its effects on products liability law. The nature and impact of the Restatement (Third) of Torts: products liability s. 10; post-sale duty to warn
• Abstracts: Monetary costs and benefits of crime prevention programs. Punishment and crime across space and time. Predictors, causes, and correlates of male youth violence
• Abstracts: Employment law; harassment. Employment law; employee piracy. Employment law; the at-will doctrine

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