Under new IRS guidelines (Revenue Procedure 95-10) issued January 17, 1995, a foreign company qualifying as a partnership must have at least two shareholders. In Addition: It must lack two of the following four" corporate characteristics":Continuity of Life
A foreign company lacks continuity of life if local law or the operating agreement provides for automatic dissolution after the "death, insanity, bankruptcy, retirement, resignation, or expulsion" of any shareholder involved in management. This list must apply to all shareholders. If all the events on this list are not selected as triggers for dissolution, those that are must provide a "meaningful possibility" of dissolution.