transcript   Transcript

Cross-Border Partnership Planning and Developments

Recorded on: Feb. 9, 2018
Running Time: 01:16:58

Full Transcript:

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Taken from the Web Program International Tax Issues 2018 held February 2018 in New York

Cross-Border Partnership Planning and Developments [01:16:58]

  • Inbound investment through partnerships, Grecian Magnesite and Rev. Rul. 91-32
  • Territorial planning for pass-through structures (i.e., use of blockers)
  • Revised Section 163(j) as applied to partnerships
  • Income sourcing
  • Loans to foreign partnerships
  • Joint venture arrangements through partnerships

Ari Berk, Peter H. Blessing, Joseph M. Calianno, Karen Lohnes

The purchase price of this Web Program segment includes the following article from the Course Handbook available online:

  • In Search of a Normative Theory of Partnership Taxation for International Tax (or How We Learned to Stop Worrying and Love Subchapter K)
    Christopher Trump, Mark A. Graham

Presentation Material
  • Cross-Border Partnership Planning and Developments
    Ari Berk, Peter H. Blessing, Joseph M. Calianno, Karen Lohnes
    Ari Berk ~ Deloitte Tax LLP
    Peter H. Blessing ~ KPMG LLP
    Joseph M. Calianno ~ BDO USA, LLP
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