Question: Suppose entity E is formed in country X by US 1 and US 2 , who are individual residents of the United States. So long

Suppose entity E is formed in country X by US

1

and US

2,

who are individual residents of the United States. So long as E is not a per se corporation, the owners have flexibility to have E be treated as what type

(

)

of entities for US tax purposes?

Multiple Choice

a disregarded entity

a foreign corporation or a partnership

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