the district court later held that a “corporation or other entity may ... be
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any 10% US shareholder of a foreign corporation (determined on December
if the foreign corporation is either a controlled foreign
a joint investigation by the Australian Broadcasting Corporation and
the best corporation or exhibitor of the year
” it may elect on Form 8832 to be taxed as a corporation. 13 If an SMLLC does not elect to
the QSub regulation treats a QSub as a corporation for employment and
the SMLLC is the successor to the corporation
the SMLLC is liable for the corporation's taxes that remain unpaid
as applied to a domestic corporation that owns a
2004-2 CB 119 (holding that where a domestic corporation and its wholly
absent an election to be treated as a corporation).
and we thank the Carnegie Corporation of New York and the
Fang and Nick Surgey. “Chinese Corporation Alibaba Joins Group Ghostwriting
the QSub regulation treats a QSub as a corporation for employment and