Читать книгу International Taxation - Adnan Islam - Страница 39

1 Determining whether a foreign business operation constitutes a separate corporation for U.S. tax purposes will not affect theAmount and the timing of available foreign tax credits.Applicability of the pass-through rules of Subpart F.Applicability of other deferral rules of Subchapter C.Deductibility of expenses attributable to domestic or foreign-sourced income.

2 Several types of business entities are “per se corporations” and are always treated as corporations for federal tax purposes. What does not fall into this category?A business entity organized under any foreign laws specifically identified in the 1996 regulations as analogous to state incorporation laws.An entity subject to tax as an insurance company.A business entity wholly owned by a foreign government.A single-member LLC.