He presumably would have done so by relying on a special IRS "safe harbor" rule relating to the taxation of a service partner's receipt of such interests, but that rule emphatically does not apply to an interest when sold to a retirement plan, which is supposed to be measured by its true fair market value.

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This can be entered, together with the receipt number, on a web page maintained by the Beijing Local Taxation Bureau.

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In addition, the rule permits the centralization and management of intellectual property in a foreign company and the receipt of royalties from related foreign subsidiaries without current U.S. taxation.

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