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law refers to wholly owned foreign subsidiaries and majority owned corporate joint ventures as CFCs.
Since "check the box" regulations cleared the way, LLCs have become popular vehicles for various types of corporate joint ventures. Mr.
Traditionally, corporate joint ventures concerned with limiting liability formed a third corporate entity, which couldn't be an S corporation because of the shareholders' corporate status.
As corporate joint ventures proliferate for compelling reasons -- such as allowing companies to share technology, reduce high capital costs, and limit risk exposures -- the LLC continues to be the joint venture vehicle of choice.
Tax Planning for Corporate Joint Ventures, Partnerships and Other Strategic Alliances (3 vols.) Numerous Authors Practising Law Institute, 1996 and supp.
A key exception to the repeal of APB 23 is unremitted earnings of foreign subsidiaries and foreign corporate joint ventures; calculating the U.S.
We strongly believe that tax laws should not erect artificial barriers to conducting business, especially abroad, and the rules must be flexible enough to accommodate structures (like corporate joint ventures) effectively dictated by foreign law or similar requirements.

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