The IRS has published a private letter ruling on Treas. Reg. §301.7701, confirming a private limited company with two 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 202551009]
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