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 […]

Read More… from Classification of Foreign Entities for the U.S. Tax Purpose