USA-FEDERAL-STATE-COMPANY-TAX.COM
A LOWTAX NETWORK SITE
 USTAXNETWORK.COM:
NEWSLETTER

To receive our free monthly network newsletter enter your email address below:

ADVERTISING

ADVERTISE ON THIS SITE!

Our sites have more than 100,000 visitors every day. Like our inter-national site, this new US site will quickly grow to be one of
the most-visited American tax sites.

If you want to advertise with us, be an exclusive launch partner for new US sections, or show our highly-rated news content on your own site, just e-mail paul@usa-tax-news.com.

We'll get right back to you! If you give us a number to call you, we'll do just that.

HOME | CONTACT US | ABOUT US | LEGAL | LINKS
> Information provided on this site is for general guidance only and is often simplified. Actual IRS procedures are complex, and taxpayers should obtain professional assistance or use IRS sources for complete information.

Summary Of Corporate Forms A summary of the tax characteristics of different corporate forms.

Domestic International Sales Corporation Now defunct, the DISC was used in conjunction with Foreign Sales Corporations.

Limited Partnership Limited Partnerships are often used for investment-holding purposes, and have 'pass-through' status for domestic partners.

Limited Liability Company LLCs are treated as partnerships unless they opt to be treated as corporations.
"S" Corporation "S" Corporations have a 'pass-through' tax treatment.


Limited Partnership

In a Limited Partnership, one or more ‘general" partners manage the business while 'limited' partners contribute capital and share in the profits but take no part in running the business. General partners remain personally liable for partnership debts while limited partners incur no liability with respect to partnership obligations beyond their capital contributions.

The Limited Partnership has been very widely used for investment purposes. In the last 30 years, most major financial companies have used the LP form to channel private capital into real estate, oil and gas and mezzanine financing. These LPs are normally structured to be long-term investments (typically 10 to 15 years with extension rights at the partnership's option) and do not make any liquidity provision in the event the investor decides to sell their partnership interest prior to the termination of the LP.

Normally, death, disability, or withdrawal of a general partner dissolves the partnership unless the partnership agreement provides otherwise or all partners agree, in writing, to substitute a general partner. Death or incompetence of a Limited Partner has no effect on the partnership.

The Family Limited Partnership (FLP), which is simply a Limited Partnership used by one family, has become the leading form for asset protection and estate planning in the US. But there are some legal dangers in many states, where a creditor is permitted to “foreclose” on a partnership or LLC interest. A “foreclosure” is a seizure of the debtor’s interest and that is a very powerful weapon for the plaintiff. Thus, an asset protection structure using an FLP must also protect ownership interests with a trust.

In May, 2005, the US Treasury and the Internal Revenue Service finalized regulations on the tax withholding obligations of US partnerships that include foreign partners.

Foreign individuals were subject to US tax for income from doing business in the US, in addition to income earned in the US through a partnership. To ensure the tax gets collected the IRS requires that partnerships withhold tax on behalf of the foreign partner.

The final rules, first proposed in September 2003, provided guidance on how to determine a foreign partner's share of partnership income and to calculate withholding tax and payment dates. The matter of interest, penalties and extra taxes for failure to comply with the regulations were also addressed.

In addition, the Treasury also issued related proposed and temporary rules covering certain tax and non-tax attributes of a foreign partner for purposes of determining tax withholding obligations.

Summary Of Corporate Forms A summary of the tax characteristics of different corporate forms.

Domestic International Sales Corporation Now defunct, the DISC was used in conjunction with Foreign Sales Corporations.

Limited Partnership Limited Partnerships are often used for investment-holding purposes, and have 'pass-through' status for domestic partners.

Limited Liability Company LLCs are treated as partnerships unless they opt to be treated as corporations.
"S" Corporation "S" Corporations have a 'pass-through' tax treatment.

LOWTAX NETWORK SITES
  Lowtax.net
  Tax-News.com
  USTaxNetwork.com
  USA-Federal-State- Company-Tax.com
  USA-Federal-State- Individual-Tax.com
  USA-International-Offshore- Company-Tax.com
  USA-International-Offshore- Expatriate-Tax.com
  USA-Sales-Use-Tax-E - Commerce.com
  USA-Investment-Tax.com
  USA-Tax-News.com
  Investors Offshore.com
  LawAndTax-News.com
  Offshore-E-Com.com
THE LOWTAX SUBSCRIPTION LIBRARY

THE LOWTAX LIBRARY

One of the web's largest and most authoritative business and investment information sources. Alongside topical, daily news on worldwide tax developments, you can receive weekly newswires or access up-to-date intelligence reports on a range of legal, tax and investment subjects.

FREE TRIAL NEWS SUBSCRIPTION

Our 16 constantly updated intelligence reports cover every important aspect of 'offshore' and international tax-planning in depth, including banking secrecy, the EU's savings tax directive, offshore funds, e-commerce, offshore gaming and transfer pricing. Reports are available for immediate downloading or as subscription services with news pages.

IMPORTANT NOTICE: THE LOWTAX NETWORK has taken reasonable care in sourcing and presenting the information contained on this site, but accepts no responsibility for any financial or other loss or damage that may result from its use. In particular, users of the site are advised to take appropriate professional advice before committing themselves to involvement in offshore jurisdictions, offshore trusts or offshore investments. All materials on this site copyright The Lowtax Network 1999 - 2007. Contact us for further information.