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11 Dec 2010, 3:00 am by Paul Caron
Thomas (J.D. 2011, Ohio State) has published Note, Garnett and Thompson: LLC and LLP Losses No Longer Passive Per Se, 5 Entrepren. [read post]
22 Jul 2009, 1:41 pm
Two recent cases have given members of an LLC greater ability to avoid the passive activity loss limitations. [read post]
10 Mar 2017, 3:59 pm by Richard Burt
  The post Ownership of Passive LLC Interest in Manager-Managed LLC Not “Doing Business” in California appeared first on San Jose Attorney and Counselor At Law - Richard G. [read post]
10 Mar 2017, 3:59 pm by Richard Burt
  The post Ownership of Passive LLC Interest in Manager-Managed LLC Not “Doing Business” in California appeared first on San Jose Attorney and Counselor At Law - Richard G. [read post]
24 May 2023, 2:59 pm by Andrew Abramowitz
Below are some tips/considerations for limiting liability in passive investments of this type: Limited Liability Entity – Ensure that the investment is made in a private company structured as an LLC or corporation. [read post]
1 Jul 2009, 2:38 pm
"Passive" losses are allowed only to the extent of "passive" income, or when the activity is sold.The IRS applied Sec. 469(h)(2), which says: Except as provided in regulations, no interest in a limited partnership as a limited partner shall be treated as an interest with respect to which a taxpayer materially participates.The taxpayers argued that LLCs and LLLPs are not "limited partners" under these rules, and they are therefore subject to… [read post]
12 Jul 2012, 4:00 am by admin
  “In 2011, the Department of Treasury then instituted new regulations for LLC Members and passive activity losses,” noted Givner. [read post]
3 Jul 2009, 2:08 am
When Sec. 469(h) was written, LLCs and LLLPs barely existed. [read post]
22 Jul 2009, 2:49 pm
Last month the Tax Court shot down an IRS argument that limited liability company losses are automatically "passive" under rules drafted for old-fashioned limited partnerships. [read post]
13 Mar 2020, 7:52 am by Stefanie Jackman
Associates, LLC and DNF Associates, LLC, in a 2-1 decision, that companies that engage third parties to collect consumer debts they acquired when the debts were in default, known as “passive debt buyers,” qualify as “debt collectors” subject to the Fair Debt Collection Practices Act (FDCPA). [read post]
10 Dec 2018, 6:44 pm by Jonas M. Grant
Nonetheless, the FTB is anticipated to continue to apply the prior Swart case narrowly, and continue to maintain that passive members of LLCs organized or doing business in California are themselves also doing business in the state. [read post]
23 Jul 2009, 6:12 am
Roger McEowen addresses recent taxpayer victories over IRS attempts to make limited liability companies "per-se passive" under the passive activity... [read post]
3 Jan 2018, 1:09 pm by Lebowitz & Mzhen
The dedicated team of Washington, D.C. product liability attorneys at the law firm of Lebowitz & Mzhen, LLC has extensive experience representing victims in all types of product liability cases, and we know what it takes to be successful on our clients’ behalf. [read post]
22 Jul 2009, 3:00 am
Section 469(h)(2) treats a limited partnership interest as presumptively passive for purposes of the passive loss rules, with the result that partnership losses cannot offset the limited partner's salary or investment income. [read post]
24 Apr 2024, 12:26 pm by Matthew Dochnal
Investors can be passive owners of the LLC while not having any responsibilities related to running the business. [read post]
22 Jun 2015, 7:38 am by Admin
New LLC’s organized to hold passive investments, such as real estate, may protect their managers under Delaware law with a properly drafted LLC operating agreement. [read post]
15 Jul 2016, 10:00 am by Katya Mezek
  In a manager-managed LLC, the members appoint a manager or managers to run and manage the LLC while the members take on a more passive role. [read post]