FACTS. HPSX is a Country X entity that is subject to Country X tax on its worldwide income. HPSX is clas- sified as a partnership for Federal tax pur- poses. P, S, and FSX, are the sole partners of HPSX. For U.S. tax purposes, P, S, and FSX each has an equal interest in each item of HPSX’s profit or loss. HPSX carries on oper- ations in Country Y that, if carried on by a U.S. person, would constitute a foreign branch within the meaning of § 1.367(a)– 6T(g)(1).
Appears in 6 contracts
Samples: Internal Revenue Service Regulation, Internal Revenue Service Regulation, Tax Regulation