Page 298 - International Taxation IRS Training Guides

Possible
Transactions (Cont’d)

 DE10

until USP
• …DE10 remained a DE USP
assets
contributed additional
of the value of
amounting to 80%

DE10 in exchange for an 80%
interest of the entity CFC2 CFC2

• Now
having more than one owner,
be disregarded. It
it can no longer
a per se classification
undergoes 20% 80%
change to a partnership (retaining
the passthrough nature of a DE) DE10 CFP10

• A Form 8832 entity change form is
not necessary

• It must now file a final Form 8858
and initial Form 8865

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