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

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 senior manager at in the Tax Advisory Division of Moore Stephens Melbourne. Simon joined the firm in 2007, prior to this Simon worked for the Australian Taxation Office where he worked in Project Wickenby having a particular focus on international tax structuring. Since joining Moore Stephens, Simon has been involved in a wide range of tax consulting and compliance activities. Working in Moore Stephens Simon has a particular focus on in International taxation and private client issues such as trusts and Division 7A. Current at 22 June 2012 Click here to expand/collapse more articles by Simon TUCKER.
 
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