A limited liability company is a relatively new business structure in the U.S., created under state statutes mostly during the 1980s and 1990s. But the Internal Revenue Service did not create a new ...
Seyfarth Synopsis: A recently published IRS memorandum provides that employees of a single-member LLC treated as a disregarded entity must be allowed to participate in a section 403(b) plan sponsored ...
As the taxable year ending December 31, 2017 approaches, the thoughts of most people turn to holidays and family gatherings, feasting and celebrations, and reflecting, perhaps, on another year gone-by ...
Is the transfer of an interest in a single-member limited liability company (LLC) — a “disregarded entity” — valued as a transfer of a proportionate share of the underlying assets owned by the LLC or ...
The Tax Court held that a sole member of an LLC was liable for the company’s employment tax liabilities because the LLC was treated as a disregarded entity in the absence of an election to be treated ...
In temporary and proposed regulations issued earlier this month, the Treasury Department clarified the self-employment tax treatment for partners of a partnership that own a disregarded entity. Let me ...
Since the adoption of the final "check-the-box" regulations in 1997, single member limited liability companies ("SMLLC" or "SMLLCs") have become one of the fastest-growing and most popular forms of ...
In 2001, the American Bar Association predicted that disregarded LLCs would eventually become the most common class of business. To the IRS, disregarded entities essentially do not exist. A business ...