Partnership

FATCA

The term partnership means a business entity that is not a corporation under paragraph (b) of this section and that has at least two members. Paragraph (b): Corporations. For federal tax purposes, the term corporation means—

  1. A business entity organized under a Federal or State statute, or under a statute of a federally recognized Indian tribe, if the statute describes or refers to the entity as incorporated or as a corporation, body corporate, or body politic;
  2. An association (as determined under § 301.7701-3);
  3. A business entity organized under a State statute, if the statute describes or refers to the entity as a joint-stock company or joint-stock association;
  4. An insurance company;
  5. A State-chartered business entity conducting banking activities, if any of its deposits are insured under the Federal Deposit Insurance Act, as amended, 12 U.S.C. 1811 et seq., or a similar federal statute;
  6. A business entity wholly owned by a State or any political subdivision thereof, or a business entity wholly owned by a foreign government or any other entity described in § 1.892-2T;
  7. A business entity that is taxable as a corporation under a provision of the Internal Revenue Code other than section 7701(a)(3); and
  8. Certain foreign entities.

UK Guidance: AEIM100860

 

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