"...discusses tax issues pertinent to international joint ventures, including [section] 482 issues, such as: control, hidden or “creeping” control, acting in concert, and burden of proof. Other tax issues discussed include those in the joint venture context, such as: choice of entity, formation of, and outbound transfers to, joint venture corporate and partnership vehicles (including the issuance of proposed regulations under [section] 367(a) and [section] 367(d) for foreign corporations and Notice 2015-54 for partnerships), check-the-box rules, blocker corporations, piercing the corporate veil, sham treatment, taxation of operating income, reporting requirements, repatriation of income, foreign tax credit planning, and joint venture termination."
Bibliography, etc. Note
Includes bibliographical references.
Formatted Contents Note
Detailed Analysis I. Introduction: "Control" II. Legal Framework III. Establishing Absence of Common Control and Arm's-Length Transactions IV. Hidden or "Creeping" Control V. Joint Venture Pricing as an Arm's-Length Comparable VI. Additional Tax Planning Issues VII. Summary of Key Reporting Obligations VIII. Conclusions Working papers.
Digital File Characteristics
Source of Description
Description based on contents viewed on September 12, 2016; title from portfolio description page.
Available in Other Form
Print version: Handler, R. Arnold, 1940- Transfer pricing. Arlington, VA : Tax Management Inc., -