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U.S. Final Reporting Regs for Foreign-Owned Domestic Disregarded Entities to Improve Transparency

14 December 2016

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Approved Changes

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United States

On 13 December 2016, final regulations (TD 9796) were published in the U.S. Federal Register that introduce reporting requirements for foreign-owned domestic disregarded entities. The collection of information under the regulations is meant to enhance the United States' compliance with international standards of transparency and exchange of information for tax purposes, and will strengthen the enforcement of U.S. tax laws. The final regulations treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for the limited purposes of the reporting, record maintenance, and associated compliance requirements that apply to 25% foreign-owned...