Entity classification update: revenue ruling 93-4

Article Abstract:

IRS revenue ruling 93-4 replaces revenue ruling 77-214 as of Feb 18, 1993, for the partnership classification of foreign entity for US tax purposes. The new ruling corrects one issue which is that the single interest theory is inapplicable to corporate continuity of life but does not address the other questions raised by 77-214. In general, 93-4 is a looser version of 77-214 which helps taxpayers. However, taxpayers should still consider stopping all transfers between subsidiaries and the parent to prevent appearance of the free transferability corporate characteristic.

Partnership, Partnerships

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A zero income tax rate for U.S. exporters

Article Abstract:

Exporters who set up foreign corporations and do not use a U.S. company may be able to defer all US and foreign income taxes, resulting in a zero income tax rate. However, many provisions of the internal Revenue Code must be carefully addressed before such a structure can be legally tax free. These include laws on source income, the use of deferrals, the definition of sales income, the nature of material participation and agent and title issues, all of which are discussed.

Management, Exports, Foreign sales corporations, Tax shelters

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Corporate expatriations - why not?

Article Abstract:

The author discusses problems with US tax laws which discourage incorporation in the US and transactions which convert US companies into foreign corporations.

United States, International, Evaluation, Economic aspects, Incorporation, Expatriation

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