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Foreign Entities Doing Business in
Tax and Treaty Considerations for Foreign Corporations
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50 percent 5th Cir acquired acquisition agent agreement amount apply assets Attorney bank basis beneficiary buy-sell agreement capital gain cash cert client closely held business Code contributions criminal tax death decedent decedent's deduction defense determining dividends earnings election ERISA ESOP estate planning estate tax evidence exemption Federal fiduciary Fifth Amendment filed foreign corporation Fourth Amendment funding gift gift tax Government grand jury immunity included income tax interest Internal Revenue Service investigation investment issue Keogh liability limited liquidation lump-sum distribution ment ordinary income participation partner partnership payments person preferred stock prior problem prosecution purchase purpose qualified plan question received redemption Regulations reorganization requirements result retirement Revocable Trust rules Section 303 shareholders shares statement statute subsidiary merger summons supra Supreme Court Tax Division tax-free taxable Taxation taxpayer tion Tonelson transaction United United States Attorney USTC valuation voting stock