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US (Delaware) LPS - Japanese Supreme Court Decision

US (Delaware) LPS - Japanese Supreme Court Decision

The Japanese Supreme Court rendered its decision that a limited partnership formed under the laws of the state of Delaware should be treated as a corporation for Japanese tax purposes on 17 July 2015.


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We have set out in this newsletter an outline of the Japanese Supreme Court Decision.


  1. Criteria for Determining Whether a Foreign Entity should be Treated as a Corporation
  2. Judgment of a Delaware LPS based on the Above Criteria
  3. Issues to Be Considered Going Forward

Japan TAX Newsletter

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