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corporation owns all the outstanding interest in a foreign legal entity that is eligible and elects to be treated as a pass through entity, it becomes disregarded for virtually all U.
In our view, the test of whether a PE arises and the concept of an "enterprise" relates to a single foreign legal entity.
Also consider the consequences of other activities, such as opening an office in a foreign country, establishing a separate foreign legal entity, and licensing your name or other intangible property to foreign concerns.