LLC lawyers are often handle the statutory conversion of state-law business corporations to LLCs. These procedures are tax-free if they are “reorganizations” within the meaning of IRC Section 361(a)(1)(F). The IRS has just released final F reorg regs. If you handle conversions of state-law business corporations to LLCs, you need to study these new regs.
For NY members of this blog and those who serve persons investing in NY state, here is a useful current post in the Farrell Fritz law firm’s blog on the taxation of closely held businesses:
Under the link below is a very recent and excellent blog post by Lou Vlahos of the Ferrell Fritz firm addressing NY tax rules affecting investment in NY real estate. I’m posting the link here in the hope that it will be useful to at least a few NY members of this blog.
Here’s the link:
Under the Check-the-Box Regulations, LLCs can elect to be taxable as S corporations, and many of them do so, especially to lawfully reduce their members’ Social Security Tax liability. Below is an excellent new post, in the Ferrell Fritz blog on the taxation of closely held businesses, on determining the fair market value of S corporation shares.
The following new law journal article provides a sophisticated discussion of the legal and tax issues in using LLCs as non-profits:
Wilson, BETTER LATE THAN NEVER: INCORPORATING LLCS INTO SECTION 4943, 48 Akron L. Rev. 485 (2015).
The three excellent new posts from Tax Analysts under the links below address Alabama LLC multi-state tax issues, but the discussions also apply to other states:
It’s not unheard of for an LLC to elect to be taxable as a C corporation but then to want to convert to a S corporation. The new post under the link below discusses the conversion:
If you’re interested in the law and taxation of family limited partnerships, you may find this article interesting:
A colleague sent me this chart. It’s not directly relevant to LLC practice, but it may be of interest for other reasons to the readers of this blog.
For those of you who are partnership tax wonks, the post sent today by Tax Analysts (the world’s best source of federal tax information, in my opinion) under the link below will be of great interest. For the rest of us: “Not so much.”
Here’s the link: http://www.taxnotes.com/tax-notes-today/14969946