More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury ...

The IRS has issued a private letter ruling on I.R.C. §7701 and Treas. Reg. §301.9100 granting two limited liability companies a 120-day extension to file Forms 8832 for classification as ...

The Tax Court has previously held that a partner who contributes his own note to a partnership in exchange for a partnership interest takes no basis in the interest and their capital account is not ...

It can be the case that companies are operating under an inferior business classification — an issue that’s more common than many would think. “They might have chosen a classification as a startup ...

For federal income tax purposes an LLC, or limited liability company, is considered a disregarded entity. In effect, the LLC does not exist under the Internal Revenue Code. Despite this fact, a ...

A limited liability company (LLC) is a legal business structure, but the IRS does not recognize an LLC as a classification for tax purposes. The IRS considers LLCs a disregarded entity for tax ...