US (Delaware) LPS - Japanese Supreme Court Decision

The Japanese Supreme Court rendered its decision that a Delaware LPS should be treated as a corporation for Japanese tax purposes on 17 July 2015.

The Japanese Supreme Court rendered its decision that a limited partnership formed ...

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

Contents

  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

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