UNITED-STATES TAX CONSIDERATIONS IN ORGANIZING A FOREIGN JOINT VENTURE

U.S. tax issues raised by the formation by a U.S. corporation and an unrelated foreign corporation of a ''50-50'' overseas joint venture, where the principal assets furnished to the joint venture by the U. S. corporation are intangible, are examined. Consideration is given to whether the joint venture should be structured as a partnership or foreign corporation, and planning suggestions are made to deal with tax pitfalls.