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- Title
Tax-Free Incorporation of a Foreign Business Enterprise: Considerations Under Section 367 of the Internal Revenue Code (or, "Monty Python and the Outbound Transfer").
- Authors
Mishik, Michael G.
- Abstract
The article addresses the effects of section 367(a) of the Internal Revenue Code on otherwise qualifying non-acquisitive nonrecognition transactions involving the transfer of assets of a U.S. person's foreign business enterprise to a foreign corporation. Among subjects discussed extensively are the exception for certain transfers of assets used in a foreign trade or business, the impact of rules relating to indirect stock transfers on a transaction, rules concerning the applicability of section 367(a) to transfers involving partnerships and certain corporations, capital contributions, and reincorporations, and special rules requiring the recapture of certain amounts in income upon a transfer of assets to a foreign corporation.
- Subjects
UNITED States; FOREIGN corporations; CORPORATE taxes; INTERNAL revenue law; TAXATION of stock transfers; TAX-exempt securities; ASSETS (Accounting)
- Publication
International Tax Journal, 2004, Vol 30, Issue 4, p10
- ISSN
0097-7314
- Publication type
Article