US Income
Limited Liability Companies (725 - 2nd)
Portfolio Description
Tax Management Portfolio, Limited Liability Companies, No. 725-2nd, focuses on the federal tax consequences of using a limited liability company (LLC) for conducting business operations. It is not a primer on the fundamentals of partnership taxation.
The tax factors in choosing an LLC are compared to regular corporations, S corporations, and partnerships as alternative business forms for tax purposes; and various uses of the LLC are summarized.
The tax consequences of converting partnerships and corporations to LLC status are discussed. Classification of the LLC is examined in detail and the unique federal tax consequences of using the LLC are discussed. Analysis and commentary are provided to the tax practitioner to assist in resolving the tax issues encountered when using an LLC.
Compensation issues are analyzed for the potential impact on LLC members. International use of the LLC is explored in detail and the state tax consequences are summarized to assist the tax practitioner in generalizing these consequences when using the LLC interstate.
For discussion of the federal tax rules as applied to partnerships, generally see 624 T.M., Audit Procedures for Pass-Through Entities; 710 T.M., Partnerships--Conceptual Overview; 711 T.M., Partnerships--Formation and Contributions of Property or Services; 712 T.M., Partnerships--Taxable Income; Allocation of Distributive Shares; Capital Accounts; 714 T.M., Partnerships--Allocation of Liabilities; Basis Rules; 716 T.M., Partnership Distributions: Death or Retirement of a Partner; 718 T.M., Dispositions of Partnership Interests; Termination of a Partnership; 720 T.M., Partnership Transactions -- Section 751 Property; 722 T.M., Family Limited Partnerships and Limited Liability Companies; 910 T.M., Partners and Partnerships -- International Tax Aspects (Foreign Income Series).
This Portfolio may be cited as Starr, Case, Garre-Lohnes, Rosenberg , Schmalz, 725-2nd T.M., Limited Liability Companies.
Elizabeth A. Case, B.A., Millsaps College; M.B.A., Southern Methodist University; formerly Special Assistant to the Deputy Chief Counsel, Internal Revenue Service; Participant, AICPA Partnership Taxation Technical Resource Panel.
Karen Garre-Lohnes, B.S., Accounting, Louisiana State University; J.D., summa cum laude, Boston University School of Law; Editor, Boston University Law Review ; member, ABA Partnership Tax Committee; author, articles published in International Tax Journal, University of Southern California Tax Institute's Major Tax Planning, The Tax Advisor .
Jeffrey I. Rosenberg, undergraduate degree, University of Rhode Island; J.D., Western New England College School of Law; LL.M. in Taxation, Georgetown University Law Center; formerly Attorney-Advisor, Passthroughs and Special Industries Division of the Office of Chief Counsel, Internal Revenue Service; speaker and lecturer, various tax institutes; author, various articles on tax issues in partnership area.
John G. Schmalz, B.A., University of Wisconsin, Milwaukee; J.D., Marquette University; formerly Attorney-Advisor, Legislation and Regulations Division, Office of the Chief Counsel, Internal Revenue Service; member, American Bar Association, Tax Section (Partnership Committee), State Bar of Wisconsin; Vice Chairman, ABA Partnership Tax Committee's Subcommittee on like-kind exchanges; author, articles published in Journal of Partnership Taxation, Journal of Taxation, Journal of Real Estate Taxation, and Journal of S Corporation Taxation .
Samuel P. Starr, B.S., Pennsylvania State University; J.D., University of Virginia; LL.M. in Taxation, Georgetown University Law Center; former member, AICPA, Partnership Tax Committee; former Chair, AICPA S Corporation Committee; former Co-Chair, ABA Tax Section Task Force on Taxable and Tax-Free Acquisitions Involving S Corporations; Adjunct Professor, Georgetown University Law Center; member, Board of Advisors, Journal of Business Entities ; Department Editor, Journal of Taxation ; speaker and lecturer, various tax institutes; author, Tax Management Portfolios 730-2nd and 731; member, State Bars of Pennsylvania and District of Columbia.
Robert J. Crnkovich, B.S., J.D., Marquette University; LL.M. in Taxation, Georgetown University Law Center; Adjunct Professor, Georgetown University Law Center; member, State Bars of Wisconsin, California, and District of Columbia.
