In PLR 202343034 (PLR), the IRS ruled that a foreign limited partnership (Entity), which is indirectly wholly owned by a foreign government through multiple "controlled entities," as defined under Temporary Treas. Reg. Section 1.892-2T(a)(3), is not a "per se" corporation for purposes of Treas. Reg. Section 301.7701-2(b)(6) or (b)(7). At issue was whether the Entity should be classified as a corporation or a partnership for US federal tax purposes. The Entity was beneficially owned by investors, some but not all of which qualified as qualified foreign pension funds (QFPF).1 If the Entity were classified as a corporation for US federal...