Much Anticipated Guidance Concerning the Federal Tax Classification of Series Issued

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On September 13, the Internal Revenue Service and Treasury issued proposed Treasury regulations addressing the federal tax classification of a series of a domestic series limited liability company, a cell of a domestic cell company, or a foreign series or cell that conducts an insurance business (the Proposed Regulations). In brief, the Proposed Regulations provide that, whether or not a series of a domestic series limited liability company, a cell of a domestic cell company, or a foreign series or cell that conducts an insurance business is a juridical person for local law purposes, it will be treated as an entity formed under local law for federal tax purposes. Furthermore, the Proposed Regulations provide that the classification of a series or cell that is treated as a separate entity for federal tax purposes generally must be determined under the same rules that govern the classification of other types of separate entities.

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