| 
A partnership is defined to mean the relationship between two or more persons to carry on a trade or business, with each person contributing money, property, labor, or skill, and each expecting to share in profits and losses. This article will provide a broad overview of some of the tax consequences of cash and property […]
This brief case note describes one of the recent cases of the U.S. tax court. This description is not a legal advice and may not be relied upon as such. On September 20, 2011, the tax court ruled in favor of the taxpayer and found that he engaged in his business activities for profit (see […]
Unlike U.S. citizens, U.S. resident aliens and domestic corporation which are taxed under the Internal Revenue Code on their worldwide income, the IRS applies a special tax regime to foreign persons. The general rule (subject to numerous exceptions) is that foreign persons are only taxed on their U.S.-source income of specified types and income effectively […]
When we are talking about nonrecognition transactions, we generally mean mergers, spinoffs, and contributions of capital. When such transactions involve foreign corporations, U.S. tax laws impose a number of reporting requirements. In this brief essay, I will generally discuss the top three reporting requirements for U.S. persons who are involved in nonrecognition transactions involving foreign […]
If a U.S. person owns or is considered to be the owner of a Foreign Disregarded Entity (“FDE”), then he must file Form 8858. In general, there are three different groups of persons who may be required to file the Form. 1. Direct “Tax Owners” of FDE The instructions to Form 8858 define a “tax […]