Guidance for former and future single-member LLCs
Article Abstract:
Two new Revenue Rulings focus on the tax consequences associated with a single-member limited liability company (LLC) taking an additional member or multiple-member LLC consolidating ownership in one owner. The rulings can help tax planners understand the IRS' position on provisions associated with a partnership termination resulting from one person purchasing all of the interest in an LLC categorized as a partnership for tax purposes. The rulings, which also indicate the various benefits of careful tax planning before engaging in such transactions, disregard an LLC as an entity separate from the owner. All of the LLC's assets are capital assets which are not subject to any debt. The rulings also discuss the importance of realizing that no debt is exists in partnership LLC conversions.
Publication Name: Practical Tax Strategies
Subject: Law
ISSN: 0040-0165
Year: 1999
User Contributions:
Comment about this article or add new information about this topic:
Tax Court splits on divorce-related stock redemptions
Article Abstract:
The author discusses the Tax Court's split decision in Read where the court held that IRC section 1041 was applicable to a stock redemption in the context of a divorce settlement. The split decision indicates that taxpayers should continue not to have confidence in the tax treatment of similar transactions.
Publication Name: Practical Tax Strategies
Subject: Law
ISSN: 0040-0165
Year: 2000
User Contributions:
Comment about this article or add new information about this topic:
Regs clarify tax on stock redemption incident to divorce
Article Abstract:
The author outlines the elements of proposed IRS regulations addressing stock redemptions that are incurred as a result of a divorce. Topics include the tax consequences of redemption, constructive distribution treatment, stock redemption treatment, and constructive distribution election.
Publication Name: Practical Tax Strategies
Subject: Law
ISSN: 0040-0165
Year: 2001
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: Is extrinsic evidence ever necessary to resolve claim construction disputes? Is extrinsic evidence ever necessary to decide claim construction disputes?
- Abstracts: Planning for the family-owned business exclusion under TRA '97. Back to basics for the family limited partnership
- Abstracts: Second City tries again; Chicago hopes new loitering law avoids constitutional defects. Standing up for victims
- Abstracts: Ethics on hold; new legislation reining in federal lawyers confuses rather than clarifies. Checkbook credibility?
- Abstracts: Eleventh Circuit invalidates FMLA designation regulation. Qualified plan issues pervading 401(k) plan mergers