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 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.