Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework ...

The issue concerns differing tax treatment of single-member US LLCs in India and the US. The position clarifies that India ...

Is the transfer of an interest in a single-member limited liability company (LLC) — a “disregarded entity” — valued as a transfer of a proportionate share of the underlying assets owned by the LLC or ...

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

Summary: As discussed in detail below, the Corporate Transparency Act (CTA) provides an exemption to its reporting requirements for certain large operating companies (the Large Operating Company ...

Since the adoption of the final "check-the-box" regulations in 1997, single member limited liability companies ("SMLLC" or "SMLLCs") have become one of the fastest-growing and most popular forms of ...

On Dec. 12, 2016, the Treasury Department and the Internal Revenue Service announced final regulations (issued in proposed form on May 5, 2016) requiring domestic disregarded entities with foreign ...

Whether an LLC is treated as a partnership or a disregarded entity for federal income tax purposes can sometimes have a significant effect on the tax consequences of a transaction. A recent order ...

Reg. section 1.904-4(a)-(q) governs the separate application of the section 904 foreign tax credit limitation to categories of income. Published January 2, T.D. 9959 added guidance to the rules in reg ...