JD Supra

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the ...
JournalofAccountancy

IRS Provides Guidance on Late Entity Classification Elections

The IRS on Thursday released Revenue Procedure 2009-41, giving eligible entities guidance on how to obtain relief when they make a late entity classification election. The relief is available for ...
JD Supra

A Narrow Aspect of the Check-the-Box Regulations that Deserves Some Press – Changing an Entity’s Tax Classification From That of a Partnership to That of an S Corporation

More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury ...
Accounting Today

IRS Offers Relief for Late Check the Box Elections

IMGCAP(1)]The IRS offers tremendous flexibility in how a foreign entity may be classified for U.S. income tax purposes. For example, by following certain procedures, a foreign entity can elect be to ...
Houston Chronicle

Can an LLC Choose to Be Taxed Differently Every Year?

For federal income tax purposes an LLC, or limited liability company, is considered a disregarded entity. In effect, the LLC does not exist under the Internal Revenue Code. Despite this fact, a ...