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  3. Law: Taxation & Customs

disregarded entity

Serbian translation: subjekat bez odvojenog poreskog tretmana

GLOSSARY ENTRY (DERIVED FROM QUESTION BELOW)
English term or phrase:disregarded entity
Serbian translation:subjekat bez odvojenog poreskog tretmana
Entered by: Miomira Brankovic

20:19 Oct 14, 2015
English to Serbian translations [PRO]
Bus/Financial - Law: Taxation & Customs / propisi o sprečavanju izbegavanja poreza
English term or phrase: disregarded entity
(nastavak teksta uz pitanje "conduit financing")
In some circumstances, instead of using a foreign affiliate as an intermediary for the FP-USA loan, FP might instead cause USA to establish a branch in FA’s jurisdiction (“DE”) and to treat that branch as an entity the separate existence of which is disregarded for U.S. tax purposes under the “check-the-box” regulations of Code section 7701. Using this structure relies on a form of regulatory arbitrage whereby (i) the loan between USA and DE is not recognized for U.S. tax purposes (because DE is treated as a branch of USA), but (ii) DE is permitted to claim the benefits of its jurisdiction’s tax treaty with the United States in accordance with Code section 894.
The finalized regulations may deny tax benefits otherwise available from U.S. tax treaties when a multi-party financing transaction is executed with a disregarded entity serving as an intermediary.
Miomira Brankovic
Serbia
Local time: 05:09
непризнати ентитет
Explanation:
disregarded entity = entity that is presented by those who created if as a separate entity but is considered by tax authorities as not being a separate entity - what is in fact "disregarded" is not the existence of whatever constitutes this "entity", namely the existence of the personnel employed, the buildings etc. is not denied, what is "disregarded/ignored" is the claim that it's a separate entity.
Selected response from:

Daryo
United Kingdom
Local time: 04:09
Grading comment
Hvala na odgovoru i živom učešću u diskusiji.
4 KudoZ points were awarded for this answer



Summary of answers provided
4непризнати ентитет
Daryo


Discussion entries: 8





  

Answers


1 hr   confidence: Answerer confidence 4/5Answerer confidence 4/5
непризнати ентитет


Explanation:
disregarded entity = entity that is presented by those who created if as a separate entity but is considered by tax authorities as not being a separate entity - what is in fact "disregarded" is not the existence of whatever constitutes this "entity", namely the existence of the personnel employed, the buildings etc. is not denied, what is "disregarded/ignored" is the claim that it's a separate entity.

Daryo
United Kingdom
Local time: 04:09
Works in field
Native speaker of: Native in SerbianSerbian, Native in FrenchFrench
PRO pts in category: 8
Grading comment
Hvala na odgovoru i živom učešću u diskusiji.
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