Search for: "Passive LLC"
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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]
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]
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]
22 Jul 2009, 7:14 am
Last month the Tax Court shot down an IRS argument that limited liability company losses are automatically "passive" under rules... [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]
9 Jul 2009, 10:46 am
No. 19 (June 30, 2009), the Tax Court held that LLC interests... [read post]
8 Jul 2009, 11:33 am
Thus, they could use all seven tests for material participation in the temporary regulations, instead of only the three available for participation of individuals that are limited partners.Under the Code Sec. 469 passive activity rules, passive activity losses cannot offset nonpassive activity income, such as wages, dividends, or profits from nonpassive activities. [read post]
3 Jul 2009, 7:28 am
The limited partner is a passive investor. [read post]
3 Jul 2009, 2:08 am
When Sec. 469(h) was written, LLCs and LLLPs barely existed. [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]
1 Jul 2009, 7:49 am
Page Perry, LLC is an Atlanta-based law firm with over 125 years collective experience representing institutional and individual investors in securities-related litigation and arbitration. [read post]
1 Jul 2009, 7:35 am
The IRS lost a battle it should never have fought yesterday in Tax Court. [read post]
29 Jun 2009, 1:54 am
Because there is so much abuse in the Schedule C loss area, we have adamantly recommended that taxpayers who are conducting a legitimate, for-profit business incorporate that business or form an LLC. [read post]
8 Jun 2009, 4:30 am
Tierney (read here my post on Seneca), he contended that deadlock between two 50% managing members of an LLC cannot provide a basis for dissolution where the LLC's sole purpose is to be a passive investor in another company. [read post]
5 Jun 2009, 7:15 am
By remaining well-versed in the current status of the law, one will better serve the client and be less uncertain when engaging in legal arguments with opposing counsel.Rather than passively skimming the case updates in Pennsylvania Law Weekly and the PBA Bar News , a better practice may be to actively committing the changes in the law to memory by typing up a running list of recent cases in one's computer. [read post]
4 Jun 2009, 2:59 am
--Court: United States District Court for the District of New MexicoOpinion Date: 4/23/09Cite: Resource Associates Grant Writing and Evaluation Services, LLC v. [read post]
26 May 2009, 6:48 am
Now, quite passive investors could afford to risk capital—but only what they chose—with entrepreneurs. [read post]
26 Apr 2009, 1:00 pm
Based on the comments I get from readers, one of the hottest topics on my blog are posts dealing with small business break-ups--be they partnerships, corporations or LLCs. [read post]
23 Apr 2009, 4:20 am
A good share of the blame for corporate governance failures (and poorly performing corporations in general belong to passive boards of directors (the members of which are often handsomely remunerated).[2] These individuals frequently serve on numerous boards while spending very little time examining the activities of the corporation - the details of which are frequently supplied by management. [read post]
28 Jan 2009, 9:40 am
Bayou Group LLC. [read post]
