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Abstract: 

Qualified REIT subsidiaries, qualified subchapter S subsidiaries, and single owner eligible entities that are disregarded as entities separate from their owners are still liable for federal tax liabilities for periods for which they were not disregarded or because there are successors or transferees of such taxable entities. This treatment is clarified in final regulations under Sections 856, 1361, and 7701.1 The final regulations adopt regulations proposed in 2004 with, as stated in the preamble, “only minor clarifying changes.”2 The final regulations are generally effective April 1, 2004.

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