HOUSE_OVERSIGHT_026596.jpg
1 MB
Extraction Summary
9
People
3
Organizations
7
Locations
0
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document (footnotes/endnotes page)
File Size:
1 MB
Summary
This document is a page of footnotes (numbers 57-72) from a legal or tax analysis document produced for the House Oversight Committee. It cites various tax regulations (Reg 1.752, Reg 1.881), treatises on partnership taxation from 2009, and specific rulings regarding Limited Liability Companies (LLCs) and Disregarded Entities (DREs). The content focuses on the technical tax treatment of pass-through entities across various US states.
People (9)
| Name | Role | Context |
|---|---|---|
| McKee | Author |
Co-author of 'Federal Taxation of Partnerships and Partners'
|
| Nelson | Author |
Co-author of 'Federal Taxation of Partnerships and Partners'
|
| Whitmire | Author |
Co-author of 'Federal Taxation of Partnerships and Partners'
|
| Fenwick | Author |
Co-author of 'State Taxation of Pass-Through Entities and Their Owners'
|
| McLoughlin | Author |
Co-author of 'State Taxation of Pass-Through Entities and Their Owners'
|
| Salmon | Author |
Co-author of 'State Taxation of Pass-Through Entities and Their Owners'
|
| Smith | Author |
Co-author of 'State Taxation of Pass-Through Entities and Their Owners'
|
| Tilley | Author |
Co-author of 'State Taxation of Pass-Through Entities and Their Owners'
|
| Wood | Author |
Co-author of 'State Taxation of Pass-Through Entities and Their Owners'
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| WG&L |
Publisher of cited tax treatises
|
|
| Cleveland Browns Transportation LLC |
Subject of a tax ruling (TSB-A-06(8)S) regarding transportation services
|
|
| House Oversight Committee |
Source of the document (implied by footer HOUSE_OVERSIGHT)
|
Locations (7)
| Location | Context |
|---|---|
|
State listed as imposing entity-level taxes on LLCs
|
|
|
State listed as imposing entity-level taxes on LLCs
|
|
|
State listed as imposing entity-level taxes on LLCs
|
|
|
State listed as imposing entity-level taxes on LLCs
|
|
|
State listed as imposing entity-level taxes on LLCs
|
|
|
State listed as imposing entity-level taxes on LLCs
|
|
|
State listed as imposing entity-level taxes on LLCs
|
Key Quotes (3)
"Alabama, California, New Jersey, New York, Pennsylvania, Tennessee, and Texas are a few of the states that impose various entity-level taxes or fees on LLCs."Source
HOUSE_OVERSIGHT_026596.jpg
Quote #1
"sales of transportation services to an operating entity by its wholly owned and income tax disregarded LLC were recognized for sales tax purposes"Source
HOUSE_OVERSIGHT_026596.jpg
Quote #2
"The proposed regulation does not expressly apply to any DREs not within the ambit of the check-the-box regulations."Source
HOUSE_OVERSIGHT_026596.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,270 characters)
57
Reg. 1.752-2(k)(3).
Reg. 1.752-2(k)(3).
58
See, e.g., McKee, Nelson & Whitmire, Federal Taxation of Partnerships and Partners (WG&L, 2009), ¶ 8.02[8].
See, e.g., McKee, Nelson & Whitmire, Federal Taxation of Partnerships and Partners (WG&L, 2009), ¶ 8.02[8].
59
Fenwick, McLoughlin, Salmon, Smith, Tilley, and Wood, State Taxation of Pass-Through Entities and Their Owners (WG&L, 2009), Appendix, Tables 8 and 9. Alabama, California, New Jersey, New York, Pennsylvania, Tennessee, and Texas are a few of the states that impose various entity-level taxes or fees on LLCs.
Fenwick, McLoughlin, Salmon, Smith, Tilley, and Wood, State Taxation of Pass-Through Entities and Their Owners (WG&L, 2009), Appendix, Tables 8 and 9. Alabama, California, New Jersey, New York, Pennsylvania, Tennessee, and Texas are a few of the states that impose various entity-level taxes or fees on LLCs.
60
Fenwick, McLoughlin, Salmon, Smith, Tilley, and Wood, State Taxation of Pass-Through Entities and Their Owners (WG&L, 2009), ¶18.03.
Fenwick, McLoughlin, Salmon, Smith, Tilley, and Wood, State Taxation of Pass-Through Entities and Their Owners (WG&L, 2009), ¶18.03.
61
Id.
Id.
62
54 AFTR 2d 84-5072, 735 F2d 704, 84-1 USTC ¶9505 (CA-2, 1984).
54 AFTR 2d 84-5072, 735 F2d 704, 84-1 USTC ¶9505 (CA-2, 1984).
63
Pennsylvania Personal Income Tax Guide (03/06).
Pennsylvania Personal Income Tax Guide (03/06).
64
See e.g., Cleveland Browns Transportation LLC, TSB-A-06(8)S, 03/06/06 (sales of transportation services to an operating entity by its wholly owned and income tax disregarded LLC were recognized for sales tax purposes).
See e.g., Cleveland Browns Transportation LLC, TSB-A-06(8)S, 03/06/06 (sales of transportation services to an operating entity by its wholly owned and income tax disregarded LLC were recognized for sales tax purposes).
65
REG-113462-08, 12/22/08.
REG-113462-08, 12/22/08.
66
Reg. 1.881-3(a)(2)(i)(A).
Reg. 1.881-3(a)(2)(i)(A).
67
Reg. 1.881-3(a)(2)(ii)(A).
Reg. 1.881-3(a)(2)(ii)(A).
68
Reg. 1.881-3(a)(1).
Reg. 1.881-3(a)(1).
69
Supra note 65.
Supra note 65.
70
Prop. Reg. 1.881-3(a)(2)(i)(C). The proposed regulation does not expressly apply to any DREs not within the ambit of the check-the-box regulations.
Prop. Reg. 1.881-3(a)(2)(i)(C). The proposed regulation does not expressly apply to any DREs not within the ambit of the check-the-box regulations.
71
Id.
Id.
72
Supra note 65.
Supra note 65.
HOUSE_OVERSIGHT_026596
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document