Page 271 - International Taxation IRS Training Guides

How Can GTOC Analysis
Help? (Cont’d)

Proper labeling is important!

(e.g., Controlled Foreign
 Distinguish the type of entity
The Box (CTB),
Corporation (CFC), Check

(DE), Foreign Disregarded Entity
Disregarded Entity

(FDE), Controlled Foreign Partnership (CFP), etc.)

and FDEs, are “disregarded” from their owner for US
• DEs
purposes but are “regarded” for legal
income tax
purposes. (e.g.,
single member Limited Liability Company
which Checked-the-Box, etc.)
(LLC), Disregarded Entity
 Show actual direct ownership

• It is important to include each entity in the diagram,
understand
showing the actual ownership structure to fully
the structure and identify
potential issues

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