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Internal Revenue Service › Employee Benefits › Disregarded Entities

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Robinson & Cole LLP

IRS Clarifies Benefit Coverage Requirements for Employees of Tax-Exempt Disregarded Entities

Robinson & Cole LLP on

The Internal Revenue Service (IRS) recently issued General Counsel Memorandum 201634021 (Memorandum), clarifying benefit coverage requirements for employees of a disregarded LLC wholly owned by a single member tax-exempt...more

Seyfarth Shaw LLP

IRS Says Employees of Disregarded Single-Member LLC May Participate in Parent’s 403(b) and 457(b) Plans

Seyfarth Shaw LLP on

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 by its parent 501(c)(3)...more

Miles & Stockbridge P.C.

IRS Clarifies that Indirect Owners of Disregarded Entities Are Liable for Self-Employment Tax

Miles & Stockbridge P.C. on

The IRS recently released temporary regulations clarifying that an employee of a disregarded entity is liable for self-employment tax if the employee is a partner in the partnership that owns the disregarded entity. See...more

Proskauer - Tax Talks

New IRS Regulations Subject Certain Partners to Self-Employment Taxes

Proskauer - Tax Talks on

On May 3, 2016, the U.S. Department of the Treasury issued new temporary and proposed regulations (Temp. Treas. Reg § 301.7701-2T) addressing the tax treatment of partners of a partnership that is the sole owner of an entity...more

Manatt, Phelps & Phillips, LLP

Partners Are Not Employees, Yet

Manatt, Phelps & Phillips, LLP on

Recently the IRS issued guidance in the form of temporary and proposed regulations clarifying that individuals who are partners in a partnership that itself owns a disregarded entity are not to be treated as employees of the...more

Latham & Watkins LLP

Partnerships: IRS Extends Prohibition on Treating Partners as Employees

Latham & Watkins LLP on

Employees of partnerships, LLCs or their disregarded entity subsidiaries who receive equity in such entities may be treated as “self-employed” for tax purposes. On May 3, 2016, the US Treasury Department (Treasury)...more

Eversheds Sutherland (US) LLP

Neither a Partner nor Employee Be: Treasury and the IRS Issue Regulations Clarifying the Employment Tax Treatment of Partners in...

Eversheds Sutherland (US) LLP on

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued temporary regulations (Regulations) clarifying the federal employment tax treatment of the owners of partnerships and other entities...more

Williams Mullen

New Regulations Squash Planning Tool for Avoiding Self-Employment Tax and Related Employee Benefit Issues

Williams Mullen on

Tax practitioners often face this issue: client is a limited liability company taxed as a partnership for federal income tax purposes (“LLC”), and it wants to issue equity to a current employee (“Individual”) without...more

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