--On 21. september 2004 23:50 -0400 John C Klensin <john-ietf@xxxxxxx> 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
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