Using partnerships in international tax planning

Article Abstract:

Multinational partnership forms should be covered under the IRS's proposed check-a-box elective entity classification system. Partnerships and hybrid business entities, which are characterized as partnerships for tax purposes in one nation and as corporations in another country, have become increasingly common ways of limiting tax liability in both outbound business planning by US multinationals and inbound planning by foreign companies. A check-a-box elective system would be a practical way of facilitating the growing global use of partnership forms.

International aspects, Tax planning, Partnership, Partnerships, Tax elections, international

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The introduction of a single European currency

Article Abstract:

Gain or loss recognition from currency exchanges made by qualified business units is controlled by IRC section 988. US tax treatment of the introduction of the single European currency will determine the effect of this section and realization section 1001. Tax neutral treatment has been advocated by many who believe that change in the tax treatment of transactions with such a significant trading partner of the US would be problematic.

Tax Law, Public Finance Activities, Other General Government Support, Coinage & Currency, Money, Euro (Currency), European Union

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Almost a merger: achieving cross-border shareholder unity without a shareholder exchange

Article Abstract:

The authors discuss cross-border stock-for-stock exchanges and their tax inefficiencies, and suggest policy changes to eliminate these inefficiencies.

United States, Acquisitions and mergers, Stock transfer

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