U.S. Model Treaty, Article 4 (Residence)
U.S. Model Treaty, Article 22 (Limitation on Benefits)
Comtek Expositions, Inc. v. Commissioner, No. 03-40597 (2d Cir. 2004), aff'g T.C. Memo. 2003-135 (despite expense sharing arrangement, no joint venture between domestic and foreign corporations in absence of agreement to divide profits from activity)
Rev. Rul. 2006-3 (Yugen Kaisha, which will become a Tokurei Yugen Kaisha under recently enacted Japanese legislation, will continue to be eligible to elect its U.S. entity classification)
TAM 200540010 (Contractual arrangement classified as business entity under Treas. Reg. § 301.7701-2)
PLR 200522006 (For treaty purposes, taxpayer is direct owner of shares in U.S. company that are directly owned by wholly-owned, disregarded entities of taxpayer)
PLR 200250005 (Foreign corporation granted extension to elect partnership classification)
Rev. Proc. 2002-15, 2002-6 I.R.B. 490 (Relief for certain untimely initial entity classification elections)
SCA 199950009 ("Commuter" green cardholder - person who holds INS Form I-551 Alien Registration Receipt Card and elects "commuter" option instead of full U.S. resident option - will be considered U.S. resident for income tax purposes until lawful permanent resident status has been revoked, or administratively or judicially determined to have been abandoned; contrary statement in INS Examination Handbook is erroneous) (note: statement in INS Handbook may have been based on pre-1985 law; see, e.g., Rev. Rul. 76-82, 1976-1 C.B. 192)
PLR 9831007 (Joint venture classified as partnership -- Section 7701)
Form 8832 Entity Classification Election (September 2002)
Form 8833 Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b) (Rev. December 2000)
Form 8840 Closer Connection Exception Statement for Aliens (2004)
Form 8854 Initial and Annual Expatriation Information Statement (Rev. May 2005)
Form 8854 Instructions (Rev. May 2005)
Form 9003 Additional Questions to be Completed by All Applicants for Permanent Residence in the United States
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