transcript   Transcript

Cross-Border Partnership Planning and Developments

Recorded on: Feb. 8, 2017
Running Time: 01:14:14

Full Transcript:

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Taken from the Web Program International Tax Issues 2017 recorded February, 2017 in New York.

Cross-Border Partnership Planning and Developments [01:14:14]
  • Inbound investment through partnerships, including Rev. Rul. 91-32
  • Income sourcing
  • IP planning – Notice 2015 – 54 (partnership aspects)
  • Loans to foreign partnerships
  • Joint venture arrangements through partnerships
  • Section 385 considerations for partnerships

The purchase price of this 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
    Jennifer H. Alexander, Peter H. Blessing, Joseph M. Calianno, Karen Lohnes
Peter H Blessing ~ KPMG LLP
Joseph M Calianno ~ BDO USA, LLP
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