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 ...

Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework includes a step-by-step guide and example.

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 ...

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 ...

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 ...

The Internal Revenue Service and the Treasury Department issued a notice Wednesday saying they intend to issue proposed regulations withdrawing the disregarded payment loss rules for multinational ...

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 ...

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 ...

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 ...

The IRS issued final regulations (T.D. 9553) Tuesday clarifying the treatment of disregarded entities with respect to employment and certain excise taxes. The rules adopt proposed regulations issued ...

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 ...