Archive of entries posted on May 2013

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

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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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U.S. Domestic LLC

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What is a Limited Liability Company?

When you are planning to start a small business, one of considerations is what business form can provide personal protection to the business owner while also providing flexibility to run the business itself. The LLC offers the best of both —the limited liability feature of a corporation and the flexibility of partnership. A Limited Liability Company (LLC) is an unincorporated business structure registered under state statute.

Tax Classification of a Limited Liability Company (LLC)

Although an LLC is a legal form of business,

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