For example, USP could engage in tax planning so that DREl is a foreign partnership instead of a foreign disregarded entity, or USP could structure its intercompany agreements so that USP is not the payer of the revenue to DREL
If DREl is treated as a foreign partnership, it is no longer treated as a disregarded entity for U.
DRE Estabelecimentos N % DREN 1863 81,0 DREC 1505 91,1 DREL
1257 58,0 DREA 309 78,4 DREAlg 133 72,3 Total 5067 55,0
The dissolved oxygen level in the tanks was maintained above 6 mg/L by an air pump (ADP-2200, Jinlai Pump Factory, China), and was measured using a Hach kit (model DREL
2400; Hach Company, CO).