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 ...
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 IRS issued temporary regulations intended to halt the practice some partnerships have adopted of treating partners as employees of a disregarded entity owned by the partnership so they can be ...
The court of appeals affirmed a tax court decision. The court held that a single-member LLC’s status as a disregarded entity did not preclude its classification as a pass-thru partner. In 2001, Robert ...
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