IRS T.D.: Entities Wholly Owned by Indian Tribal Governments Not Separate Entities (I.R.C. §§6417)

The IRS published final regulations clarifying the Federal tax classification of entities wholly owned by Indian Tribal governments. The regulations provide that entities wholly owned by Tribes and organized under Tribal law generally are not recognized as separate entities for Federal income tax purposes. However, these entities are treated as separate for Federal employment tax purposes and certain Federal excise tax purposes. The regulations also clarify rules for entities owned by multiple Tribes and provide that the wholly owned requirement can be met through ownership by other disregarded entities. The final regulations apply to taxable periods beginning on or after ...