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Dual-Chartered Entity Question Set
What is a dual-chartered entity?
When a government of jurisdiction issues a charter to form a corporation or other corporate entity, the newly formed entity must adhere to the laws, regulations, and tax codes pursuant to that jurisdiction's vested authority. There are several provisions of the United States tax code, however, that allow for a corporate entity to be formed in more than a single jurisdiction, and these so-called dual-chartered entities are bound by certain limitations, while being afforded other privileges and benefits. Scholarly research on the construction of current tax codes demonstrates that "the United States also has special rules for 'dual-chartered' entities (i.e., those entities that are treated as formed in more than one jurisdiction) ... See Treas. Reg. §301.7701-2(b)(9) (treating dual-chartered entities as per se entities...
Many advantages can be derived from forming a dual-chartered entity, because "similar to dual-resident companies, dual-chartered entities that are formed in the United States continue to be taxed as domestic corporations" (Rubinger, 2007).
2.) What are the potential abuses when a foreign entity chose to be treated as a partnership for U.S. tax purposes?
The entry of a foreign company into the lucrative U.S. market is an especially critical process for executives and financial analysts, because the U.S. tax code allows foreign entities to be treated in a number of distinct ways depending on how they are formed. When a foreign entity elects to be treated as…
References
Amatucci, A., Gonzalez, E., & Trzaskalik, C. (2006). International tax law. Kluwer Law International.
Rubinger, J.L. (2007). Moving the "management and control" of a foreign corporation to achieve favorable u.s. tax results, part i. The Florida Bar Journal,81(9), 70-79. Retrieved from http://www.floridabar.org/divcom/jn/jnjournal01.nsf/Author/507571A279ABBA8385257 363005FE5A1
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