Japan’s National Tax Agency (NTA) today released a statement concerning the tax treatment of income derived through a U.S. limited partnership by Japanese resident partners.
The statement (English) [PDF 8 KB] was posted on the tax agency’s website, and was released in response to concerns that a U.S. limited partnership would be treated as an “opaque entity” after a 2015 decision of Japan’s Supreme Court. In that decision, the Supreme Court held that a U.S. Delaware limited partnership was to be treated as a corporation for Japanese tax purposes.
In today’s statement, the NTA clarified:
Read a February 2017 report [PDF 94 KB] prepared by the KPMG member firm in Japan
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