In PLR 202343034 (PLR), the IRS ruled that a foreign limited partnership (Entity), which is indirectly wholly owned by a foreign government through multiple "controlled entities," as defined under Temporary Treas. Reg. Section 1.892-2T(a)(3), is not a "per se" corporation for purposes of Treas. Reg. Section 301.7701-2(b)(6) or (b)(7). At issue was whether the Entity should be classified as a corpo…