Classification of foreign trusts for US tax purposes : they may be called trust, but don't trust the label

Resource Information

The work Classification of foreign trusts for US tax purposes : they may be called trust, but don't trust the label represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Classification of foreign trusts for US tax purposes : they may be called trust, but don't trust the label

Creator

• Miller, M.J

Subject

• entity classification
• trust
• partnership
• check-the-box regulations

Language

eng

Summary

Since the United States adopted the 'check-the-box' regulations in 1996, the task of classifying a business entity as a partnership or a corporation has, in most instances, become quite simple. In the case of a eligible entity that wishes to be classified as a partnership (or, wholly owned, a disregarded entity) the now-ancient art of manipulating a four-factor test (and preparing costly legal options) has been replaced by a procedure that literally involves little more than checking a box to achieve the desired classification. The check-the-box regulations did not change the rules for distinguishing business entities from trust, but in the purely domestic context, the distinction has diminished importance

Citation source

In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 63 (2015),

Geographic coverage

North America

Language note

English