Classification of Foreign Entities for the U.S. Tax Purpose

The entity classification regulation under IRC 7701 (”the check-the box regulation”) allows unincorporated business entities to choose their classification for federal tax purpose under an elective regime.

Eligible business entities

Certain business entities are by definition classified as corporation under Treas. Reg. § 301.7701-2(b). They are often referred as to as “per se” corporations and not eligible for election. The “per se” corporations for federal tax purposes include entities incorporated under federal or state law,

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Summary of Foreign Information Reporting for U.S. Citizens and Residents

The Internal Revenue Service (IRS) requires U.S. taxpayers who have currency or property invested in foreign countries to file information returns in connection with their foreign holdings and certain foreign transactions they may have engaged in.   There are substantial monetary penalties for failure to file these returns in a timely fashion.

Form TD F 90-22.1 – Report of Foreign Bank and Financial Accounts (FBAR). If you have a financial interest in or signature authority over a foreign financial account,

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