Review of Selected Entity Classification and Partnership Tax Issues

Review of Selected Entity Classification and Partnership Tax Issues PDF Author: United States. Congress. Joint Committee on Taxation
Publisher: Congress
ISBN:
Category : Business & Economics
Languages : en
Pages : 64

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Book Description
Distributed to some depository libraries in microfiche.

Review of Selected Entity Classification and Partnership Tax Issues

Review of Selected Entity Classification and Partnership Tax Issues PDF Author: United States. Congress. Joint Committee on Taxation
Publisher: Congress
ISBN:
Category : Business & Economics
Languages : en
Pages : 64

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Book Description
Distributed to some depository libraries in microfiche.

Review of Selected Entity Classification and Partnership Tax Issues

Review of Selected Entity Classification and Partnership Tax Issues PDF Author: William V. Roth, Jr.
Publisher:
ISBN: 9780756701154
Category :
Languages : en
Pages : 56

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Book Description
A review, in late 1996, of recent developments in the tax rules governing entity classification taxation of the income of partnerships. This review was undertaken under the Committee's duties to investigate the operation & effects of the Federal tax system, to investigate the administration of the Federal tax system by the IRS & other Federal agencies, & to make such other investigations of the Federal tax system as are necessary. This report sets forth issues relating to the tax treatment of partnerships & the classification of entities as corp. or partnerships. Describes possible proposals relating to the tax treatment of partnerships. Discusses & analyzes issues relating to entity classification.

Review of Selected Entity Classification and Partnership Tax Issues

Review of Selected Entity Classification and Partnership Tax Issues PDF Author:
Publisher:
ISBN:
Category : Business enterprises
Languages : en
Pages : 56

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Book Description


Income Taxation of Fiduciaries, and Beneficiaries 2008

Income Taxation of Fiduciaries, and Beneficiaries 2008 PDF Author: Byrle M. Abbin
Publisher: CCH
ISBN: 9780808091837
Category : Law
Languages : en
Pages : 1084

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Book Description
Income Taxation of Fiduciaries and Beneficiaries provides step-by-step guidance on the taxation of fiduciary income. This comprehensive guide for practitioners advising fiduciaries and beneficiaries in federal and state income tax matters covers the broad range of complex issues from charitable remainder trusts to nexus rules and their effect. Providing expert practical advice, Income Taxation of Fiduciaries and Beneficiaries helps the practitioner obtain the most advantageous outcomes for his/her fiduciary and beneficiary clients. Key feature: 35 case studies with filled-in forms 1041 and accompanying documents.

Reports of the United States Tax Court

Reports of the United States Tax Court PDF Author: United States. Tax Court
Publisher:
ISBN:
Category : Government publications
Languages : en
Pages : 442

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Book Description


Reports of the United States Tax Court

Reports of the United States Tax Court PDF Author: United States. Tax Court
Publisher: Government Printing Office
ISBN:
Category :
Languages : en
Pages : 450

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Book Description


Double non-taxation and the use of hybrid entities

Double non-taxation and the use of hybrid entities PDF Author: Leopoldo Parada
Publisher: Kluwer Law International B.V.
ISBN: 940354676X
Category : Law
Languages : en
Pages : 531

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Book Description
The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.

Federal and State Taxation of Limited Liability Companies 2009

Federal and State Taxation of Limited Liability Companies 2009 PDF Author: David J. Cartano
Publisher: CCH
ISBN: 9780808019138
Category : Business & Economics
Languages : en
Pages : 984

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Book Description
Federal and State Taxation of Limited Liability Companies provides clear and reliable guidance on what the latest tax treatment is for limited liability companies and what it means for your clients or your business. It answers all of your questions with an analysis of all federal tax issues applicable to LLCs with detailed references to related Code Sections and Treasury Regulations, plus cases, revenue rulings and private letter rulings. It provides a state-by-state analysis of state tax laws and filing requirements in all 50 states and the District of Columbia, with references to the applicable tax forms and places of filing listed. It explains how to prepare the most common LLC tax forms, state tax forms, checklists, practice tips, tables, and examples. This comprehensive manual offers scrupulous and exhaustive coverage of LLC taxation that accountants, tax attorneys, and CPAs working with LLCs will find invaluable.

Study of the Overall State of the Federal Tax System and Recommendations for Simplification, Pursuant to Section 8022(3)(B) of the Internal Revenue Code of 1986: Recommendations of the staff of the Joint Committee on Taxation to simplify the federal tax system

Study of the Overall State of the Federal Tax System and Recommendations for Simplification, Pursuant to Section 8022(3)(B) of the Internal Revenue Code of 1986: Recommendations of the staff of the Joint Committee on Taxation to simplify the federal tax system PDF Author:
Publisher:
ISBN:
Category : Fiscal policy
Languages : en
Pages : 612

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Book Description


Study of the Overall State of the Federal Tax System and Recommendations for Simplification, Pursuant to Section 8022(3)(B) of the Internal Revenue Code of 1986: Study of the overall state of the federal tax system

Study of the Overall State of the Federal Tax System and Recommendations for Simplification, Pursuant to Section 8022(3)(B) of the Internal Revenue Code of 1986: Study of the overall state of the federal tax system PDF Author: United States. Congress. Joint Committee on Taxation
Publisher:
ISBN:
Category : Fiscal policy
Languages : en
Pages : 620

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Book Description