Tag Archives: federal tax

International Tax Advisory: Through the Looking Glass: Reporting by Foreign-Owned Disregarded Entities

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In the wake of the Panama Papers leak, the IRS and Treasury have announced proposed regulations to require significant reporting by foreign-owned domestic disregarded entities. Our International Tax Group considers the implications of this anticipated regulatory burden.

Federal Tax Advisory: General Utilities Repeal and Spins

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Our Federal Tax Group notes IRS concerns about Section 355 tax-deferred spinoffs, including the relevance of the 1986 repeal of the General Utilities doctrine.

Click here to view the entire advisory on the Alston & Bird website.

The Cloudy Status of a “Profits Interest” Holder as an LLC Member

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Cumulus Radio Corp. v. Olson, U.S. Dist. Ct., C.D. Ill., March 10, 2015 The existence of federal jurisdiction in this case turned on whether an individual who held an unvested profits interest in a limited liability company (“LLC”), and whom the LLC considered a partner for tax purposes, was a “member” of the LLC under Delaware law.  The case illustrates some of the confusion commonly surrounding the nature of LLCs, LLC membership, and “profits interests.” Defendant Alpha at first admitted being a Delaware “corporation,” which, if true, would have given the court diversity jurisdiction.  [...]Read more