The hybrid entities or reversal hybrid entities meant an incentive for aggressive tax planning. (iv) The term pass-through entity means a partnership, S corporation, or any other person (whether domestic or foreign) other than a corporation to the extent that the income or deductions of the person are included in the income of one or more direct or indirect owners or beneficiaries of the person. It is not by chance that the financial sector took clear advantages through the special purpose vehicles, structured arrangements, loan and credit transactions and parking of assets for tax purposes. The misuse of hybrid entities offered a powerful tool for tax minimization on local and foreign earnings.
Any financial entity that is highly leveraged relative to the amount of. More specifically, the Final Regulations treat 'API Gains' (i.e.
The hybrid entities are the result of the discordances between different jurisdictions, qualifying them at the same time as corporation or pass-through. the price risks arise from the potential change in the value of assets that. The US check-the-box rules, since 1997, have produced a boost to international tax arbitrage. It doesn't make sense to allow certain taxpayers to choose whether they are a corporation or not. Hybrid Entities Why Not Tax Pass-throughs as Corporations? Hybrid Entities Why Not Tax Pass-throughs as Corporations?
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