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New Proposed Regulations on Tax Treatment of Series LLCs and Protected Cell Companies  


Author:  F. Roy  Sedore.


Source: Volume 24, Number 03, January/February 2011 , pp.48-54(7)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

On September 14, 2010, the Internal Revenue Service issued Proposed Regulations 1 regarding the U.S. tax treatment of a series of a domestic series limited liability company (LLC), a cell of a domestic protected cell company, and a foreign series or protected cell that conducts an insurance business.

Keywords: Prop. Treas. Reg. Sec. 301.6011-6, Prop. Treas. Reg. Sec. 301.6071-2, Prop. Treas. Reg. Sec. 301.7701-1, cell companies, segregated account companies, series LLCs, rent-a captives, captive insurance transactions

Affiliations:  1: Baker & McKenzie LLP.

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