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Federal Tax Classification of Series LLCs

 

Gain a better understanding of tax classification issues surrounding series LLCs.

Series LLC can be a powerful tool for the right client, allowing for liability separation with a single entity. However, poorly defined and developed Series LLCs can create numerous tax headaches for the practitioner. Failure to understand the limitations of Series LLC will result in an entity that has many difficulties with properly reporting taxes, determining who the employer is, properly defining assets and liabilities, control issues, etc. This material will review the history and development of the Series LLC with the goal of understanding the best practices in using these entities to minimize possible issues. Internal Revenue Service rulings and regulations, as well as recent uniform laws, will be explored to give practitioners the tools to understand current Series LLC issues as well as the ability to understand future developments.

Agenda

Faculty

Michael S. Goode, J.D., LL.M.

Michael S. Goode, J.D., LL.M.

Lewis Thomason

  • Counsel at Stites & Harbison, PLLC, a law firm with offices throughout the Southeast United States
  • Focuses on tax, business, estate planning and international law
  • Chair of the tax section of the Tennessee Bar; vice-chair of the estate planning section of the Tennessee Bar and member of the Atlanta International Tax Study Group
  • Has written and taught CLEs on Series LLCs, as well as on many other tax and corporate issues
  • Has formed many Series LLC entities and has helped real estate attorneys with deed issues with Series LLCs
  • In addition to Series LLCs, he has practiced in a variety of tax, corporate and estate planning areas, from writing new pension legislation under state law for a large county school district, to reviewing and creating new tax provisions for large merger and acquisition transactions, to serving as the business attorney for a mid-sized Asian company purchasing its first United States factory, to assisting a European executive with his foreign account reporting issues and negotiations with the IRS
  • LL.M. degree in taxation, New York University; J.D. degree, William and Mary
  • Can be contacted at 404-680-6295 or [email protected]

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