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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