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.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1998
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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.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1996
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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.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 2000
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- 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
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