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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.

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

Japan TAX Newsletter

© 2020 KPMG AZSA LLC, a limited liability audit corporation incorporated under the Japanese Certified Public Accountants Law and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. © 2020 KPMG Tax Corporation, a tax corporation incorporated under the Japanese CPTA Law and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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