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Treaty Shopping: Is It Still a Viable Option? |
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Modern U.S. income tax treaties contain a “limitation on benefits” provision to prevent treaty shopping, defined as “the use, by residents of third states, of legal entities established in a Contracting State with a principal purpose to obtain the benefits of a tax treaty between the United States and the other Contracting State.” Still, older treaties, such as those with Egypt, Hungary and Poland, potentially allow a foreign investor to repatriate profits out of the United States at a significantly reduced withholding rate without incurring any additional foreign income taxes. Jeffrey L. Rubinger, in his article in Corporate Business Taxation Monthly, examines structures that may be utilized for an inbound foreign investor to reduce or even eliminate U.S. federal income tax burdens.
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Parents Balk at Signing Estate Documents that Might Create Slacker Offspring |
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Many estate planning professionals find themselves frustrated in their efforts to gain clients’ cooperation in completing the process. Clients don’t want their hard work and success to result paradoxically in their children being unmotivated or lazy. Stephen Goldbart and Joan DiFuria, in their column in Practical Estate Planning, share their experience in preserving family wealth past three generations while turning anxiety into the optimal financial and values-based formula.
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New Rules on Partnership Allocations of Foreign Taxes |
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On Oct. 18, 2006, the IRS issued final regulations on partnership allocations of foreign income tax. These new rules modify and clarify the proposed and temporary regulations issued in 2004. Under Code Sec. 704(a), a partner’s distributive share of income, gain, loss, deductions and credits is determined by the partnership agreement, however, those allocations must have “substantial economic effect” under Code Sec. 704(b). Paul C. Lau, Nora Stapleton and Brian Carter examine the final regulations in their article in Taxes—The Magazine.
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Code Sec. 108(e)(8)(B) Adds Another Twist to Debt vs. Equity Considerations |
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A key provision of the American Jobs Creation Act of 2004 received almost no attention yet is extremely important. Failure to address the potential implications of Code Sec. 108(e)(8)(B) properly could yield a very costly tax issue at a time when the entity owners can least afford it—upon exiting a failed venture. Joseph F. Schlueter, in his article in Journal of Passthrough Entities, addresses several aspects of Code Sec. 108(e)(8)(B), including an analysis of the law prior to its enactment, the strategic issues it presents, and structuring considerations.
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 Read this article from the Journal of Passthrough Entities |
| Subscribe to the Journal of Passthrough Entities |
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Contractors, Construction and Building Your Own Tax Exposure |
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Construction contractors face some of the more perennially complicated issues in sales and use taxation. Generally, the problems stem from one of three related issues: the nature of the work undertaken, the type of contract language used, and the different types of sales a contractor may make. John Healy and Bruce Nelson, in their column in Journal of State Taxation, don hardhats and take you through the dangerous tax areas of contract jobs on real property, time and material work on real or tangible property, over the counter retail sales and more.
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| Read this article from the Journal of State Taxation |
| Subscribe to the Journal of State Taxation |
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| Stay informed on key new business taxation developments |
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Journal of Practical Estate Planning |
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| Valuable advice and practical insights from experienced estate planning practitioners to help you help your clients |
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Taxes—The Tax Magazine |
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Insightful articles and columns on current tax issues, trends and hot topics |
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Journal of Passthrough Entities |
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| Unparalleled insights for implementing tax-saving business strategies and transactions with partnerships, S corps, LLCs, and other passthroughs |
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Journal of State Taxation |
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| Guidance and workable solutions from leading tax specialists on how to reduce your company’s or client’s state and local tax liabilities |
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Maximizing Foreign Tax Credits to Eliminate Double Taxation
Audio Seminar |
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| Learn the ins and outs of the foreign tax credit and how to maximize the FTC to eliminate double taxation |
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| Thursday, May 31st at 1pm Eastern, noon Central. Register now for this insightful program! |
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