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Japan Clarifies Treatment of U.S. Limited Partnerships as Fiscally Transparent

|Approved Changes|Japan-United States
Japan-United States

Japan's National Tax Agency (NTA) issued a release on 9 February 2017 concerning the tax treatment under Japanese law of income derived by Japanese partners through a U.S. Limited Partnership (U.S. LP). The release provides clarification given a 17 July 2015 Japanese Supreme Court decision that Delaware LPs should be treated as opaque entities and not as fiscally transparent entities. That dec…

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