https://www.taxtmi.com/article/detailed?id=11782 The GloBE rules treat entities fiscally transparent where created as flow-through entities, with special measures when such an entity is the Ultimate Parent Entity. Flow-through entities are split into Tax Transparent Entities-transparent in both creation and owner jurisdictions-and Reverse Hybrid Entities-transparent where created but opaque to owners-resulting in divergent tax timing and allocation; the rules apply separately from each owner's perspective so income and tax consequences may be partially attributed based on each owner's domestic characterization. en-us Sat, 26 Aug 2023 08:24:55 +0530 Sat, 26 Aug 2023 08:24:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=11782 The GloBE rules treat entities fiscally transparent where created as flow-through entities, with special measures when such an entity is the Ultimate Parent Entity. Flow-through entities are split into Tax Transparent Entities-transparent in both creation and owner jurisdictions-and Reverse Hybrid Entities-transparent where created but opaque to owners-resulting in divergent tax timing and allocation; the rules apply separately from each owner's perspective so income and tax consequences may be partially attributed based on each owner's domestic characterization. Articles Other Topics Sat, 26 Aug 2023 08:24:55 +0530 https://www.taxtmi.com/article/detailed?id=11782