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- Title
International Tax Issues Corner.
- Authors
Forst, David
- Abstract
The article discusses the U.S. Tax court case involving Warwick Trading Co. into a contribution agreement with Lojas Arapua SA, which is in bankruptcy reorganization under Brazilian law. It mentions that shortly after transferring its receivables, Arapua was redeemed out of its purported partnership with Warwick. It informs that Warwick had not made a Code Section 754 election, the Code Section 743(b) adjustment to the basis of partnership property did not apply in the case.
- Subjects
UNITED States; WARWICK Trading Co.; TAX courts; LOJAS Arapua SA; BUSINESS partnerships; ACCOUNTS receivable; TAX &; expenditure limitations
- Publication
Journal of Passthrough Entities, 2011, Vol 14, Issue 6, p21
- ISSN
1099-7407
- Publication type
Article