partnershipstransparententitydouble tax conventionoecdmodel conventionThe OECD states in the work entitled : 'Model Tax Convention on Income and On Capital, Volume 1 Taxation, Section II.2, Differences that affect the tax treatment of partnerships' that most member countries "recognise the concepts of...
Addressing the ramifications of a decision striking down the mandatory repatriation tax on the tax system, Justice Sonia Sotomayor noted that the provision is similar to the tax treatment of partnerships, S-corporations and foreign corporations controlled by U.S. taxpayers. "These are ...
Incorporated partnerships have a separate legal personality from their partners, meaning they are considered juridical persons for legal and tax purposes. This means that the partnership can enter into contracts, own property, and sue or be sued in its own name. Examples ...
The Revenue Procedure provides that the receipt of a “profits interest” for the “provision of services to or for the benefit of a partnership in a partnership capacity or in anticipation of being a partner” is not taxable. A profits interest, in turn, is defined as any partnership ...
Because of the difference in treatment, a hybrid entity provides many tax advantages and tax planning opportunities. We offer a full range of services to accommodate the onerous provisions applicable to US partners in foreign partnerships, including Preparation of Form 8865 "Return of US Person With...
The new exemption for qualifying limited partnerships should eliminate the uncertainty surrounding the tax treatment of partnerships with foreign minority partners, ensuring that new housing developments are treated similarly, regardless of whether the development is being undertaken by a Canadian-controlled ...
the tax treatment of partnerships, trusts and estates, and accounting aspects; - the basic jurisdictional principles adopted by the US with respect to appli... JR Repetti,DM Ring,PR Mcdaniel - Kluwer Law International 被引量: 43发表: 2005年 Taxation of Distributions from Accumulation Trusts: Th...
The tax treatment of cross-border partnerships under model-based tax treaties : some lessons from Grundlingh v The Commissioner for the South African Revenue Service : notes The case dealt with the tax treatment of a cross-border partnership under a bilateral tax treaty patterned on the OECD's...
BUSINESS partnershipsLIQUIDATIONTAXATION of corporate profitsALLOCATION (Accounting)TAX reformThe term "carried interest" is typically used to refer to profits interests issued by investment partnerships to their manager(s). It is an ownership interest in a partnership that has no liquidation value at ...
Drnevich and Sternburg, “Publicly Traded Partnerships: Tax Treatment of Investors,” 50The Tax Adviser276 (April 2019) Hagy, “Reporting Publicly Traded Partnership Sec. 751 Ordinary Income and Other Challenges,” 49The Tax Adviser252 (April 2018) ...