Page 283 - International Taxation IRS Training Guides
P. 283
Commonly Understood Symbols
(Cont’d)
Hybrid partnership: Treated as a
HP flow-through for US tax
USP
US parent corporation purposes; treated as a
corporation in the country of
organization
Reverse hybrid corporation –
Treated as a corporation for US
Controlled foreign
CFC
corporation RH tax purposes; treated as a flow-
through entity in the
country of
organization
Disregarded entity that is
owned directly by a US
A true domestic branch (US and
DE company – treated as a BR foreign tax purposes)
branch for
US tax purposes;
corporation in the country of
organization
A true foreign branch (US and
DE Disregarded entity for US FBR foreign tax purposes)
tax purposes, corporation in
the country of organization
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