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- R. John Smith
New Jersey, New York
R. John Smith, Esq., is a tax law expert with over 30 years focus upon Partnership Tax law matters. He is author of the treatise "Practical Insights on Tax Law“, Tax Law Writer and Editor of Tax Law CPE courses; works closely with national subject matter professionals in the design and execution of complex, large-scale partnership transactions, has lectured on complexities of Subchapter K, partnership modeling Debt allocations, distributions, bringing in new partners, sales of partnership shares, terminations, US Treasury proposed partnership regulations on hot assets under Code Sec. 751(b). which mandate bookups (revaluing partnership assets at fair market value) to lock in each partner’s share of Code Sec. 751 property; nuances of joint venture structuring, US Taxation of international transactions, U.S. International Taxation,Cross-Border Transfers,taxation of outbound transfers to, as well as inbound transfer from, foreign corporations is determined under Code Sec. 367; Reorganizations,Outbound Transfers to Foreign Corporations; Acquisitive Reorganizations;Outbound Acquisitive Reorganizations;Inbound Transfers From a Foreign Corporation;Inbound Acquisitive Reorganizations; Foreign-To-Foreign Acquisitive Reorganizations; Foreign currency translations, Hedges of Foreign Currency Risk with Debt Instruments held as Capital Assets; Tax Law Strategy for tax attributes including foreign Qualified Business Unit earnings remittances, foreign corporation actual and deemed distributions, foreign income taxes etc. throughout the US, Israel, Asia etc. He is member of the U.S. Tax Court Bar and the U.S. Supreme Court Bar. Jack is an alumni of Harvard University and New York University School of Law.
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