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The international interaction of the US check-the-box regulations

The Tax Specialist | 1 Aug 09
 
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Published on 01 Aug 09 by "THE TAX SPECIALIST" JOURNAL ARTICLE

In 1997 the US Federal Treasury introduced the check-the-box (C-T-B) regulations to simplify and to provide certainty to how entities are defined and classified under US Federal tax law. The regulations permit an entity to elect its own classification, be it a corporation or a fiscally transparent entity. When these regulations apply to foreign entities, certain tax arbitrage opportunities can be created. This article explores these opportunities and looks at how Australia’s tax laws have adapted to the US regulations.

Author profile

Simon Tucker CTA
Simon is a Partner at Shine Wing. - Current at 06 August 2018
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