Rev. Rul. 73-254

A United States citizen contributed assets and, thereby, became a member of an unincorporated business organization that was established under an instrument pursuant to the laws of a foreign country.

Held, the tests and standards which will be applied in classifying the unincorporated business organization as a partnership, as a trust, as an association taxable as a corporation, or as some other taxable entity will be determined under Section 7701 of the Code and the regulations thereunder. However, it is the local law of the foreign jurisdiction that must be applied in determining the legal relationships of the members of the organization among themselves and with the public at large, as well as the interests of the members of the organization in its assets.