Can Uninsured National Banking Associations Receive Pass-through Tax Treatment Under Entity Choice Regulations?
Author: Staff Editors.
Source: Volume 19, Number 03, January/February 2006 , pp.42-45(4)
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Abstract:
When an unincorporated state-chartered trust company converts to a national banking association pursuant to 12 U.S.C. 35, is the resulting association an eligible entity under Reg. 301.7701-3(a) that can continue to receive pass-through treatment for federal income tax purposes? The issue was recently raised in a letter to the Treasury Tax Legislative Counsel by the law firm representing Brown Brothers Harriman Trust Company LLC (“BBHTC-NY”), a limited liability trust company organized under the laws of New York, which the Office of the Comptroller of the Currency permitted to convert to a national banking association.Keywords:
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