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.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 2000
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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.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1996
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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.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1996
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- Abstracts: Regulating gene data; U.S. and E.U. may implement restrictions on patent rights and statutues to protect privacy
- Abstracts: Structuring U.S. operations for foreign corporations in the current tax climate. Partnerships can be restructured to meet changing needs
- Abstracts: New wine in old skins: interaction of new COBE regulations and the substantially all requirement. "Regular, normal distributions" and the substantially all requirement