Japan's National Tax Agency (NTA) issued a release on 9 February 2017 concerning the tax treatment under Japanese law of income derived by Japanese partners through a U.S. Limited Partnership (U.S. LP). The release provides clarification given a 17 July 2015 Japanese Supreme Court decision that Delaware LPs should be treated as opaque entities and not as fiscally transparent entities. That decision was in relation to losses claimed by Japanese individual taxpayers that had invested in U.S. real estate through Delaware LPs. According to the release: In light of 2005 tax reform (newly introduced loss limitation rules for foreign partnerships),...