Planning for Current Distributions from an LLC
LLC distributions most frequently occur when an LLC distributes operating cashflow or refinancing proceeds or liquidates a member’s interests. But distributions can also be used to accomplish the LLC’s...
Published on May 10, 2010
LLC Distributions of Contributed Property
An LLC member who makes a contribution to the LLC of property with an FMV different from its basis may be required to recognize gain or loss upon a subsequent distribution of the contributed property to another member
Published on September 30, 2012
Handling Gifts and Bequests of LLC Interests
The gift of an LLC interest generally does not result in the recognition of gain or loss by the donor or the donee
Published on May 14, 2010
The CPAS Role in Reviewing LLC Allocations
...Sec. 704(a) provides that a partner’s allocation of taxable income, gain, loss, deduction, and credit is determined in accordance with the partnership agreement. A limited liability company (LLC) classified as a partnersh
Published on April 19, 2010
The Practitioners Role in Reviewing LLC Allocations
Sec. 704(a) provides that partnership allocations are determined in accordance with the partnership agreement, but an LLC classified as a partnership does not have a partnership agreement. This item discusses how such LLC allocations can be made
Published on October 04, 2011
Converting a C Corporation into an LLC
Converting a C corporation into a limited liability company (LLC) allows the C corporation shareholders to continue to have limited liability while acquiring the advantages of passthrough taxation, but the heavy tax cost of the conversion normally will be...
Published on January 28, 2011
U.S. LLCs for U.K. Tax Purposes
What are the global tax implications for LLC members who are not U.S. residents
Published on October 23, 2013
Electing S Corporation Status for a Limited Liability Company
In some situations, business owners have state-law reasons for wanting their business to be formed as a limited liability company, but for tax purposes they would prefer S corporation (rather than partnership) tax treatment.
Published on December 02, 2013
Planning Considerations When Converting a C Corporation to an LLC
The authors discuss when shareholders should consider a conversion from a C corporation to an LLC. Possible disadvantages are explored, and tax costs and benefits are assessed
Published on February 01, 2011
Now Is the Time Converting a C Corporation to an S Corporation or LLC
The current uncertain economic environment may present an opportunity to exit C status and its attendant double taxation at an acceptable current tax cost.
Published on July 30, 2013