Now showing items 1-5 of 5
Contribution of S Corporation Stock to Disregarded Limited Partnership Did Not Terminate S Election
An S corporation’s sole shareholder transferred all of his stock shares to two newly formed, wholly owned disregarded LLCs. The LLCs then transferred the stock shares to a newly formed state limited partnership that the ...
LLC Remains Patent Holder of Asset for Capital Gain Purposes
Three co-inventors obtained patents for their inventions. Later, in exchange for membership interests in a new LLC, the inventors transferred their interests in the product to the company. The IRS ruled that the LLC was ...
Court Allows Direct Foreign Tax Credit for Tax Paid by Disregarded Entity
A direct foreign tax credit was proper when a company organized under Luxembourg laws by a U.S. parent company made or accrued advanced corporate income tax payments to Luxembourg. The company’s members did not have joint ...
Activities of Disregarded Entity Do Not Create UBTI
A Section 501(c)(6) trade group formed a wholly owned disregarded limited liability company for the purpose of providing trade show services. The IRS ruled that the activities of the disregarded LLC did not create unrelated ...
S Election Did Not Trigger Recapture of Dual Consolidated Losses Where Closing Agreement Was Signed
A discussion of an IRS ruling stating that under certain circumstances, an S corporation election would not trigger a dual consolidated losses recapture if a closing agreement was entered into by the parent company, its ...