Tax Issues for Banks Using Disregarded Entities to Segregate Business Units
Author: James D. Goeller.
Source: Volume 24, Number 04, March/April 2011 , pp.55-58(4)
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Abstract:
Banks, in particular, should understand the implications of using disregarded entities for holding assets within their Group, whether using a QSub or a single-member LLC. The tax treatment under the Subchapter H provisions of the Code may not apply to the assets held within the disregarded entities and could result in a trap for the unwary.Keywords: IRC Section 166 conformity election; Rev. Rul. 2007-32; Rev. Proc. 2007-33; single-member LLC; QSub
Affiliations:
1: Perry-Smith LLP.