U.S. tax issues raised by the formation by a U.S. corporation and an u
nrelated foreign corporation of a ''50-50'' overseas joint venture, wh
ere the principal assets furnished to the joint venture by the U. S. c
orporation are intangible, are examined. Consideration is given to whe
ther the joint venture should be structured as a partnership or foreig
n corporation, and planning suggestions are made to deal with tax pitf
alls.