Brazilian FIPs and the Check-the-Box Election for US Federal Tax Purposes

Some foreign entities have the ability to take advantage of the U.S. “check-the-box” election. Celso Grisi and Maria Carolina Grecco Bazzanelli of Mayer Brown explain how Brazilian private equity investment funds would probably fall within the concept of “business entities” and could therefore be eligible to make a “check-the-box” election for U.S. federal tax purposes.