American Accounting Association 2006 Midwest Region Meeting March 30 – April 1 Chicago, Illinois

Friday, March 31, 10:20 a.m.-12:00 noon Concurrent session 2C - Fraud, Ethics, Equity and Partnerships (Taxation)

Title: International Partnership Taxation:  An In-Depth Look at the Unresolved Issues

Martin Kamenski                                   James P. Trebby PriceWaterhouseCoopers                       Marquette University Milwaukee, WI

ABSTRACT:  The purpose of this research is to examine several key issues in international partnership taxation arrangements which either remain unresolved or at least heavily disputed.  The first issue involves the definitions and technical treatment of partnerships as an international vehicle.  A second issue concerns international tax planning.  The third issue for international partnership taxation agreements involves their use by businesses.  Often, a corporation may realize tax savings by establishing a partnership with another corporation to form a subsidiary.  On the other hand, a foreign corporation may benefit by conducting business in the United States as a partnership instead of incorporating.  These unique areas of interest bring to light several interesting questions surrounding international partnership taxation which this paper will discuss.

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