Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s ...

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 ...

Single entrepreneurs own a large number of small businesses in the United States. While many businesses continue to operate as sole proprietorships, the benefits of organizing a single member limited ...

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 ...

On Tuesday, the IRS issued proposed regulations (REG-154159-09) that provide rules regarding who is the “taxpayer” for purposes of applying the IRC § 108 discharge of indebtedness rules to a grantor ...

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 ...

On Dec. 12, 2016, the Treasury Department and the Internal Revenue Service announced final regulations (issued in proposed form on May 5, 2016) requiring domestic disregarded entities with foreign ...

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 ...

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Many tax-exempt organizations have formed single-member limited liability companies (SMLLCs) as integral parts of their entity structure. SMLLCs enjoy flexible treatment for tax purposes, limitation ...

We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...