Federal & State Taxation of Limited Liability Companies
Description:
Federal and State Taxation of Limited Liability Companies provides clear and reliable guidance on what the latest tax treatment is for limited liability companies and what it means for your clients or your business. This hands-on treatise is dedicated entirely to the taxation of LLCs. It answers all of your questions with an analysis of all federal tax issues applicable to LLCs with detailed references to related Code Sections and Treasury Regulations, plus cases, revenue rulings and private letter rulings. It provides a state-by-state analysis of state tax laws and filing requirements in all 50 states and the District of Columbia, with references to the applicable tax forms and places of filing listed. It explains how to prepare the most common LLC tax forms, state tax forms, checklists, practice tips, tables, and examples. This comprehensive manual offers scrupulous and exhaustive coverage of LLC taxation that accountants, tax attorneys, and CPAs working with LLCs will find invaluable for daily reference. The 2006 Edition of Federal and State Taxation of Limited Liability Companies brings you up to date on the latest developments including: - Impact of the American Jobs Creation Act of 2004 and the Working Families Tax Relief Act of 2004 on LLCs - New cases and rulings regarding the use of an LLC by a charitable organization, including the rules on unrelated business taxable income and participation by a charitable organization as a member or manager of an LLC - Election classification procedures, when LLCs are automatically classified as corporations, late classification elections, and the requirements for an LLC to elect classification as an S corporation - IRS proposed regulations issued in June 2005 that would tax the issuance of a membership interest (including profits interests, capital interests, or options to acquire a membership interest) in exchange for services. Section 6.04[D] discusses the valuation safe-harbor election and the allocation safe-harbor election that the LLC must make in its operating agreement so that members will not be taxed on receipt of a profits interests in exchange for services - Deductibility of start-up expenses after 2004 - Proposed regulations issued in 2005 regarding the disguised sales rules, and when the transfer of money, property or other consideration by a member to an LLC will be taxed as a result of a related transfer of property by the LLC to the contributing member - New reporting method for items of income, and gain, loss a deduction for an LLC that is classified as a partnership - Applicability of the deduction for manufacturing and domestic production activities to LLCs that are classified as partnerships - New built-in loss rules and allocation rules under the Working Families Tax Relief Act of 2004 - Mandatory basis adjustments that the LLC must make on distribution of assets to members - New restrictions on loss allocations and deductions under the Working Families Tax Relief Act of 2004 - Final IRS regulations issued in 2005 on the two classes of LLC liabilities, the assumption of liabilities by an LLC, and the basis adjustments that must be made as a result of the two different classes of liabilities. - Updates to the fringe benefit rules applicable to LLCs - New Section 401(k) plan contribution rules for members in an LLC - Interim IRS regulations on transfers of membership interests, loss deductions, allocations to transferee members, and basis adjustments to LLC assets following the transfer of membership interests - New self-employment tax rulings applicable to LLCs - Final IRS regulations issued in 2005 on tax liabilities of single-member LLCs - Final and temporary IRS regulations on the tax requirements applicable to LLCs if the LLC has foreign members - New withholding requirements for an LLC if the LLC has foreign members - New cases and IRS rulings in 2005 regarding the valuation discounts t
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