--On 21. september 2004 23:50 -0400 John C Klensin <john-ietf(_at_)jck(_dot_)com>
wrote:
(time to change the subject line enough to do some
differentiation)
good principle......
as I said on another thread, I think we should take competent tax advisor's
advise on whether or not we can achieve this, and how fast (unless we
dismiss the scenario for other reasons).
The two "interim plans" I have heard bandied about are:
- Start operation, but run the corporation in such a way that taxable
profits (which would normally be used to build funds) is minimized, thus
minimizing tax liability
- Incorporate, but don't transfer operations to the corporation until
tax-excempt status has been granted.
I like the first one best, because it has the least impact on the other
things that I want the reorganization to achieve, but I am not an US tax
lawyer.....
One last note: The whole tax-excempt vs taxable issue is (I believe)
exactly the same for operations organized as a subsidiary of ISOC as for
opoerations organized as a separate corporation. That's one reason why
Scenario O doesn't propose a subsidiary organization - that form seemed to
commit the sin that Brian has warned us against: Complicating things and
adding uncertainty for no easily visible gain.
Harald
_______________________________________________
Ietf mailing list
Ietf(_at_)ietf(_dot_)org
https://www1.ietf.org/mailman/listinfo/ietf