IRS PLR: Partnership with Multiple Owners Not Classified as Corporation Under Foreign Government Entity Rules (IRC §7701)

The IRS has published a private letter ruling on Treas. Reg. §301.7701, confirming that an entity with multiple owners, formed as a limited partnership for a global credit investment structure, is not classified as a corporation pursuant to Treas. Reg. §301.7701, as it is not “wholly owned” by a foreign government or entity. [PLR 202551012]

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