JD Supra

Proposed Disregarded Payment Loss Rules Create Traps for the Unwary

Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s ...

IRS Issued PLR Granting Foreign Entity Extension to File Disregarded Entity Election

The IRS issued a private letter ruling on I.R.C. §7701 and Treas. Reg. §301.9100 granting a foreign entity a 120-day extension to file Form 8832 for classification as a disregarded ...
JD Supra

Disregarded Entities Under the Check-the-Box Regulations Are Not Disregarded for All Tax Purposes

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 ...
The National Law Review

Disregarded Entity Eligibility for the CTA Large Operating Company Exemption

We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...
The National Law Review

Proposed Disregarded Payment Loss Rules Create Traps for the Unwary

We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...