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| | Curtis, Mallet-Prevost, Colt & Mosle LLP - IRS regulations - tax lawyers, check-the-box |
 | | The proposed rules provide that unless a business entity is automatically required to be classified as a corporation for U.S. tax purposes, the entity can elect the classification it wishes to apply. |
 | | Among the foreign entities that are listed in the proposed regulations as de-facto corporations are limited liability entities such as the British Public Limited Company, the French Sociéé Anonyme, the Dutch Naamloze Vennootschap, the Netherlands Antillian Naamloze Vennootschap, and the German Aktiengesellschaft. |
 | | With respect to an entity which has a single owner, the preamble to the proposed regulations notes that a partnership election is not available, since a fundamental characteristic of a partnership is the existence of associates. |
| www.cm-p.com /publications_newsletters_1996_july_rules.htm (334 words) |
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