IRS PLR: Foreign Limited Partnership with Multiple Owners Not Classified as Corporation (IRC §7701)

December 30, 2025, 9:12 PM UTC

The IRS has published a private letter ruling on Treas. Reg. §301.7701, confirming that a foreign limited partnership with at least two owners is not classified as a corporation under this regulation, allowing the partnership classification election to be respected for U.S. federal tax purposes. [PLR 202551014]

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