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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 ...
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 ...