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Disregarded Entities


Disregarded Entities
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Disregarded Entities


Disregarded Entities
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Author : Howard E. Abrams
language : en
Publisher:
Release Date : 2006

Disregarded Entities written by Howard E. Abrams and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2006 with Corporate veil categories.


... discusses entities that are recognized as having a legal status separate from their owners for certain purposes but are totally ignored for federal income tax purposes. The three types of disregarded entities are entities disregarded under the elective classification regime, qualified S corporation subsidiaries, and qualified real estate investment trust subsidiaries. For each type of entity, qualification, formation, conversion, operation, and termination issues are addressed along with use of the entity in specific contexts including corporate reorganizations, partnership transactions, and like-kind exchanges. Application of specific provisions such as the at-risk rules and the cancellation of indebtedness provisions are discussed. Use of disregarded entities in cross-border transactions and their impact on the direct and indirect foreign tax credit also are described.



Internal Revenue Bulletin


Internal Revenue Bulletin
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Author : United States. Internal Revenue Service
language : en
Publisher:
Release Date : 2003

Internal Revenue Bulletin written by United States. Internal Revenue Service and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003 with Tax administration and procedure categories.




Internal Revenue Cumulative Bulletin


Internal Revenue Cumulative Bulletin
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Author : United States. Internal Revenue Service
language : en
Publisher:
Release Date : 2006

Internal Revenue Cumulative Bulletin written by United States. Internal Revenue Service and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2006 with Tax administration and procedure categories.




Code Of Federal Regulations


Code Of Federal Regulations
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Author :
language : en
Publisher:
Release Date : 2017

Code Of Federal Regulations written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Administrative law categories.


Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries.



Marsh S California Corporation Law 5th Edition


Marsh S California Corporation Law 5th Edition
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Author : Marsh, Finkle, Bishop
language : en
Publisher: Wolters Kluwer
Release Date :

Marsh S California Corporation Law 5th Edition written by Marsh, Finkle, Bishop and has been published by Wolters Kluwer this book supported file pdf, txt, epub, kindle and other format this book has been release on with categories.




Classifying Entities And The Meaning Of Tax Transparency


Classifying Entities And The Meaning Of Tax Transparency
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Author : Michael McGowan
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-01-10

Classifying Entities And The Meaning Of Tax Transparency written by Michael McGowan and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-01-10 with Law categories.


Imposing UK tax on an entity or those linked to it involves understanding what kind of entity is being dealt with, especially when it is formed outside the UK. Is it a company, a partnership, a trust or something else? This often involves considering whether the entity is ‘tax transparent’ and if so, what that means. While of great importance, the UK tax rules for classifying entities are notoriously vague, as is the UK meaning of ‘tax transparency’. This book breaks new ground by exploring these topics comprehensively, in a world which is well aware of the problems created by entity classification mismatches. In so doing, it addresses, with emphasis on UK tax law, issues such as: the meaning of a ‘partnership’ and a ‘trust’; what is meant and is not meant by ‘tax transparency’, across a range of taxes and situations; how tax treaties have dealt with entity classification questions and related ‘transparency’ issues; how entity classification questions are impacted by EU law; and how the UK approach could be improved, policy-wise and practically, without facilitating tax avoidance. The book compares in detail the UK entity classification approach with that of the US, the Netherlands and France. Appendices consider the unusual UK capital gains tax treatment of partnerships, as well as the special transparency rules which can apply where a partnership is party to loans or derivative contracts, or owns intangible assets. Questions of entity classification and tax transparency are of fundamental importance in any mature tax system and especially in a globalised economy. This book unlocks those questions for both academics and practitioners.



Mergers Acquisitions And Buyouts December 2023 Edition


Mergers Acquisitions And Buyouts December 2023 Edition
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Author : Ginsburg, Levin, Rocap
language : en
Publisher: Wolters Kluwer Law & Business
Release Date :

Mergers Acquisitions And Buyouts December 2023 Edition written by Ginsburg, Levin, Rocap and has been published by Wolters Kluwer Law & Business this book supported file pdf, txt, epub, kindle and other format this book has been release on with categories.




Taxation Of Cross Border Partnerships


Taxation Of Cross Border Partnerships
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Author : Jesper Barenfeld
language : en
Publisher: IBFD
Release Date : 2005

Taxation Of Cross Border Partnerships written by Jesper Barenfeld and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Double taxation categories.


Aims to identify and analyse problems related to double taxation of income attributable to cross border partnerships in asymmetrical situations de lege lata. This refers to cases where the same partnership, in across border owner/entity situation, is recognized as a taxable person in one country, but as transparent for tax purposes in the other."



Mergers Acquisitions And Buyouts June 2023 Edition


Mergers Acquisitions And Buyouts June 2023 Edition
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Author : Ginsburg, Levin, Rocap
language : en
Publisher: Wolters Kluwer Law & Business
Release Date :

Mergers Acquisitions And Buyouts June 2023 Edition written by Ginsburg, Levin, Rocap and has been published by Wolters Kluwer Law & Business this book supported file pdf, txt, epub, kindle and other format this book has been release on with categories.




2018 Cfr Annual Print Title 26 Internal Revenue Part 1 1 401 To 1 550


2018 Cfr Annual Print Title 26 Internal Revenue Part 1 1 401 To 1 550
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Author : Office of The Federal Register
language : en
Publisher: IntraWEB, LLC and Claitor's Law Publishing
Release Date : 2018-04-01

2018 Cfr Annual Print Title 26 Internal Revenue Part 1 1 401 To 1 550 written by Office of The Federal Register and has been published by IntraWEB, LLC and Claitor's Law Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-04-01 with Law categories.