Alternative Business Organizations

1 Charts Showing Entity Ownership Structures Domestic Ownership Structure for Corporation Sole Shareholder CORPORATION (organized under state law) Organization of One Owner Limited Liability Company (Current U.S. Tax Reporting) U.S. Corporation Or U.S. Individual Limited Liability Company (treated as disregarded entity) 2 One Person Limited Partnership Ownership Structure 100% Individual Owner Individual S Corporation 99% Limited Partner 1% General Partner Limited Partnership Limited Liability Company Joint Venture Ownership Structure Individual Owner One Individual Owner Two 50% Member 50% Member Limited Liability Company 3 Corporate Joint Venture Ownership Structure Corporation or Individual Owner One Corporation Or Individual Owner Two 50% Member 50% Member Corporation Organization of Foreign SubsidiariesSame Country Holding Company Structure U.S. Corporation (or U.S. individual) Foreign Subsidiary One (Country X) Foreign Subsidiary Two (Country X) 4 Organization of One Owner Limited Liability Company (Current U.S. Tax Reporting) (two foreign jurisdictions) U.S. Corporation Foreign Country Limited Liability Company (treated as disregarded entity) Activities in Country X Branch Country X or Country Y Organization of Domestic Subsidiary Two Foreign Jurisdictions Operations in Second Foreign Jurisdiction Use of Limited Liability Company U.S. Corporation Domestic Subsidiary (activities in Country X) Limited Liability Company (treated as disregarded entity) Country Y 5 Organization of Foreign Subsidiary Two Foreign Jurisdictions Operations in Second Foreign Jurisdiction Use of Limited Liability Company U.S. Corporation Foreign Subsidiary Organized in Country X Limited Liability Company (treated as disregarded entity) Country Y Organization of Foreign Subsidiary Multiple Third Country Branches (Branches or Single Member LLCs) U.S. Corporation Foreign Subsidiary (Country X) Country A Branch Country B Branch Country C Branch Country D Branch 6 Organization of Joint Venture Partnership (Current U.S. Tax Reporting) U.S. Corporation Foreign Corporation (country X) 100% Owned U.S. Subsidiary Limited Liability Company or Partnership (country X) Chart Showing Use of Special Purpose Subsidiary Structure in Foreign Context to Enable Limited Liability Status Without Joint IRS Form 8832 Election U.S. Parent Corporation Special Purpose Subsidiary Structure In Foreign Context to Enable Limited Liability Status Without Joint Election Local Country Joint Venture 100% Special Purpose Third Country Limited Liability Company (e.g., Cayman Islands) 50% Interest – No limited liability in local country 50% Interest – Limited Liability Local Country Non-Per Se Entity (e.g., partnership) 7