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Foreign Entities Doing Business in
Tax and Treaty Considerations for Foreign Corporations
Legal and Financial Considerations in Acquisitions of U
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50 percent 9th Cir acquired acquisition agreement amount apply assets Attorney bank basis beneficiary buy-sell agreement capital gain cash client closely held business Code contributions criminal tax death decedent decedent's deduction defense determining dividends earnings effect election ERISA ESOP estate planning estate tax evidence exchange exemption fair market value Federal fiduciary Fifth Amendment filed foreign corporation Fourth Amendment funding gift gift tax Government grand jury immunity included income tax Internal Revenue Service investment issue Keogh liability Limited Partner Limited Partnership liquidation loss lump-sum distribution ment ordinary income participation partnership interest payments pension person preferred stock prior problem prosecution purchase purposes qualified plan question received redemption Regulations reorganization requirements result retirement Revocable Trust rules Section 303 shareholders shares statute Subchapter subsidiary merger summons supra Tax Division tax-free taxable Taxation taxpayer tion Tonelson transaction transfer treated United USTC valuation