This article provides an introduction to Sec. 956 inclusions.
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November 2017 - The Tax Adviser
- Magazine
- November 2017

FOREIGN INCOME & TAXPAYERS
ESTATES, TRUSTS & GIFTS
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 2
Part 2 of this three-part series analyzes legal and beneficial ownership concepts as applied to a trust or estate created and administered in a foreign common law jurisdiction in contrast to a civil law jurisdiction.
TAX CLINIC
CHARITABLE CONTRIBUTIONS
corporations & shareholders
EMPLOYMENT TAXES
GAINS & LOSSES
PRACTICE & PROCEDURES
procedure & administration
COLUMNS
TAX PRACTICE RESPONSIBILITIES
CAMPUS TO CLIENTS
CASE STUDY
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.