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 ...
The IRS on Thursday released Revenue Procedure 2009-41, giving eligible entities guidance on how to obtain relief when they make a late entity classification election. The relief is available for ...
The IRS recently issued general legal guidance illustrating the application of the often misunderstood relevance rules for foreign entities in various settings. 1 This article provides a brief summary ...
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