IRS PLR: Foreign Entity With Multiple Owners Not Classified as Corporation (IRC §7701)

December 30, 2025, 8:05 PM UTC

The IRS has published a private letter ruling on Treas. Reg. §301.7701, determining that a foreign entity with multiple owners is not classified as an association taxable as a corporation, pursuant to §301.7701-2(b)(6), which applies only to business entities wholly owned by a foreign government or entities described in Treas. Reg. §1.892-2T. [PLR 202551013]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.

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