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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
Simon is a Taxation Manager with Moore Stephens.
Current at 8 August 2008
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