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Foreign Entities › Check the Box Rules

Bilzin Sumberg

Navigating Pandora’s Hallelujah Mountains: Civil Law Foundations, U.S. Tax Classification and Related Penalty Issues

Bilzin Sumberg on

One of the most challenging aspects of assisting clients with international tax planning is determining the right entity to use for that client’s situation. Although the Internal Revenue Service (the “IRS”) simplified the...more

Bilzin Sumberg

It's All Relevant: Recent IRS Guidance Affecting Pre-Immigration Planning

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The IRS recently issued general legal guidance illustrating the application of the often misunderstood relevance rules for foreign entities in various settings....more

Bilzin Sumberg

Check-the-Box Elections: Relevance in the International Context

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One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

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