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Income Taxes › Internal Revenue Service › Disregarded Entities

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Ballard Spahr LLP

IRS Changes Rules for Who Can Sign a Power of Attorney for an Entity Treated as a Partnership

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Summary - In November 2022, the IRS updated its guidance regarding who can sign Form 2848, Power of Attorney and Declaration of Representative (POA), submitted on behalf of a limited liability company (LLC) treated as a...more

Foster Garvey PC

Disregarded Entities Under the Check-the-Box Regulations Are Not Disregarded for All Tax Purposes

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More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more

Dorsey & Whitney LLP

Critical Reporting Obligation: Canadian-Owned U.S. Corporations and Disregarded Entities

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Canadian persons and entities owning a significant interest in a U.S. corporation or U.S. entity classified as a “disregarded entity” for U.S. federal income tax purposes should ensure they are compliant with IRS Form 5472...more

Ballard Spahr LLP

Partners Must Pay Self-Employment Tax on Partnership Income—Even From a 'Disregarded Entity'

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The IRS has published Final Regulations finalizing its prior guidance that partners in a partnership must pay self-employment tax on their partnership income, even if they work for an entity owned entirely by the partnership...more

Foodman CPAs & Advisors

Thoughts about the New Filing Requirements for Foreign-Owned U.S. entities?

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Foreign Persons that own 25% of a US entity might want to reassess their strategy as it relates to that ownership. It “used to be” (until December, 2016) that a Foreign Person as a single owner of a Limited Liability Company...more

Akerman LLP

New Reporting Requirements For Foreign-Owned Disregarded Entities Have Taken Effect

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The final regulations enacted in late 2016 that impose new reporting requirements on foreign-owned disregarded entities have now taken effect, bringing changes that will add significant complexity for many taxpayers this tax...more

Stinson LLP

Minnesota Corporate Franchise Tax Change for Foreign Disregarded Entities

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The Minnesota Department of Revenue issued its position on foreign disregarded entities of corporate taxpayers on October 4, 2017. In response to the Minnesota Supreme Court decision filed August 2, 2017 in Ashland Inc. v....more

Ballard Spahr LLP

Treating Partners as Employees – Overview and Update

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Limited liability companies (LLCs) have become the fastest-growing entity choice for businesses in recent years. LLCs provide flexibility in operations and distributions. However, to the surprise of many businesspeople, if an...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

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On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Miles & Stockbridge P.C.

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

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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

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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

Latham & Watkins LLP

Partnerships: IRS Extends Prohibition on Treating Partners as Employees

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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...

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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

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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

Proskauer Rose LLP

Wealth Management Update - September 2015

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September Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The September § 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more

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