Impact of Rev. Proc. 95-10 on foreign entity classification

Abstract

Members attending a conference during the American Bar Association Section of Taxations' 1995 Midyear Meeting were especially interested in IRS Associate Chief Counsel Robert E. Culbertson's understanding of the application of Rev. Proc. 95-10 to the classification of foreign limited liability-type companies. Although the panel, of which Culbertson was a member, as well as the attendees, were appreciative of the guidance provided by the procedure, there was an expressed concern that it is not as helpful in the foreign context as it could be.