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Final regulations issued on classification of business entities organized in multiple jurisdictions

16 March 2006

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Approved Changes

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United States

The US Treasury Department and Internal Revenue Service (IRS) have issued final regulations on the tax classification of business entities organized in multiple jurisdictions (so-called dual chartered entities). The final regulations were issued under the US check-the-box rules. The final regulations replace temporary regulations issued on this topic on 12 August 2004; for a report on the temporary regulations. The final regulations adopt the two principal rules of the temporary regulations that: (i) an entity organized in more than one jurisdiction will be treated as a corporation for US tax purposes if it takes a form in any of those...