TABLE OF CONTENTS
CHAPTER 1: CAPITAL ASSETS AND TRANSACTIONS
- Timing of Deposits 1-9
- The Technical Workings of the Fund 1-6
- Tender Vessels and Employment Tax Issues 1-2
- Problems for Sole-proprietors 1-5
- Non-Qualifying Withdrawals 1-12
- Mortgage Payments 1-10
- Minimum Deposits 1-9
- Maximum Deposits 1-8
- Investments of the Fund 1-9
- Investment Tax Credit 1-12
- How the Program Works 1-5
- Fund Deposits 1-8
- Definition of Assessable Financial gain Ascribable to Operations of a Schedule A Vessel 1-9
- Definition of Agreement Vessel 1-7
- Capital Construction Funds 1-4
- Basis Reduction 1-10
- Audit Issues 1-2
- Vessels: Descriptions and Depreciable Lives 1-1
CHAPTER 2: FOREIGN BUSINESS CONSIDERATIONS
- Treatment of Fixed and Ascertainable Payments to Foreign Individuals 2-3
- Treatment of Alien Partner's Distributive Shares 2-2
- Transfer Cost Issues Under IRC section 482 --
- Special Audit Tools: Directed Summons Under Section 982 and Designation of Agent for Domestic-Controlled Business to Secure Information from a Dominant Foreign Corporation or Entity Under IRC section 6038A 2-10
- Sales of Tangible Property; and Payments to Related Entities for Management Fees,Commissions, etc., at Another than Arm's-Length 2-5
- IRC section 982 2-10
- IRC section 6038A 2-10
- IRC Section 482: Remove Evaluation 2-6
- How and Why Foreign Interests Play Such Important Roles 2-1
- Foreign Crew: Employees and Independent Contractors 2-11
- Earnings Denudation -- IRC section 163(j) 2-4
- Overview of the Market
