5 February 2001 Internal T.I. 2000-0062927 F - Société civile française -- summary under Section 96

A French civil partnership had attributes that were more similar to those of a partnership than of a corporation, so that it was a partnership for ITA purposes The Directorate stated:

The fact that such an entity has legal personality under French law does not in itself prevent it from being considered a partnership for the purposes of the Act.