IRS Proposes New Treatment of LLC Members, Limited Partners Under Passive Loss Rules

In November 2011 the IRS issued proposed regulations (REG-109369-10) that would redefine “interest in a limited partnership as a limited partner” for purposes of determining material participation under the Sec. 469 passive loss rules. What that means in plain terms is that historically under Sec. 469(h)(2), losses from an interest in a limited partnership have…

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Single member LLC

Over the years, there has been confusion regarding Single Member Limited Liability Companies (SMLLCs) in general and specifically, how they can report and pay employment taxes. An LLC is a new entity created by state statute. The IRS did not create a new tax classification for the LLC when it was created by the states;…

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