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Partnerships Entity Classification

Foster Garvey PC

A Narrow Aspect of the Check-the-Box Regulations that Deserves Some Press – Changing an Entity’s Tax Classification From That of a...

Foster Garvey PC on

More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury Department are considering...more

Butler Snow LLP

Are you caught in the CRS “Triangulation Problem”?

Butler Snow LLP on

The Common Reporting Standard (“CRS”), following along the precedent set by the Foreign Account Tax Compliance Act (“FATCA”), creates the concept of “accountholders” in structures such as trusts, foundations, companies and...more

Morgan Lewis

Recent UK Court Decision on UK Tax Treatment of US LLCs

Morgan Lewis on

HMRC provides guidance on the implications of the recent case Anson v Revenue and Customs Commissioners. Delaware limited liability companies (LLCs) are regularly seen in many international corporate groups, including in...more

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