Page 40 - Large Business IRS Training Guides

Foreign Related Party

a foreign person that
• A foreign related party (“FRP”) is

with respect to the taxpayer
is a related party

any person who is not a United
• A foreign person is
States person

• A United States person is defined under
section

7701(a)(30), except that –

individual who is a citizen of any U.S. possession (but
• any
otherwise a U.S. citizen); and
not
not a U.S. resident
• who is

• is not a United States person

• Special
rules apply for partnerships (discussed further

below)

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