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2.58 MB
Extraction Summary
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People
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Locations
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Events
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Quotes
Document Information
Type:
Legal/tax policy document
File Size:
2.58 MB
Summary
This document outlines IRS regulations regarding single-owner disregarded entities (DREs), such as SMLLCs and QSubs, treating them as separate entities for employment and excise tax purposes. It details specific tax liability considerations, including successor liability in mergers and the IRS's ability to assess deficiencies and file liens against these entities.
Organizations (2)
| Name | Type | Context |
|---|---|---|
| IRS | ||
| Internal Revenue Service |
Timeline (2 events)
Issuance of final regulations under Section 1361
Updates to Employer Tax Guide
Relationships (2)
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Key Quotes (3)
"That provision treats an eligible single-owner DRE as a separate entity for certain excise tax purposes."Source
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Quote #1
"A DRE, including an SMLLC, a QSub, and a QRS, is treated as a separate entity for purposes of... Federal tax liabilities"Source
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Quote #2
"The SMLLC is liable for the corporation's taxes that remain unpaid, and, therefore, is the proper party to sign the consent to extend the period of limitations."Source
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Quote #3
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