More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). 1 The Regulations ended decades of battles between ...
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 ...
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 ...
The IRS issued temporary regulations intended to halt the practice some partnerships have adopted of treating partners as employees of a disregarded entity owned by the partnership so they can be ...
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 ...
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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 ...