Federal and State Taxation of Limited Liability Companies provides clear and reliable guidance on what the latest tax treatment is for limited liability companies and what it means for your clients or your business. This hands-on treatise is dedicated entirely to the taxation of LLCs.

It answers all of your questions with an analysis of all federal tax issues applicable to LLCs with detailed references to related Code Sections and Treasury Regulations, plus cases, revenue rulings and private letter rulings. It provides a state-by-state analysis of state tax laws and filing requirements in all 50 states and the District of Columbia, with references to the applicable tax forms and places of filing listed. It explains how to prepare the most common LLC tax forms, state tax forms, checklists, practice tips, tables, and examples.

This comprehensive manual offers scrupulous and exhaustive coverage of LLC taxation that accountants, tax attorneys, and CPAs working with LLCs will find invaluable for daily reference.

Benefits and Features

Brings You Up To Date On The Latest Developments Including:

• The changes made by the Small Business and Work Opportunity Tax Act of 2007, the Tax Relief and Health Care Act of 2006, and the Tax Increase Prevention and Reconciliation Act of 2006
• The 2007 rulings on use of an LLC by charitable tax-exempt organizations
• The rulings in 2007 on the classification of various types of LLCs, including the reasons for electing classification as a corporation rather than a partnership
• The election by spouses under the Small Business and Work Opportunity Tax Act of 2007 to treat an LLC as a qualified joint venture, with all items of income, gain, loss, deduction and credit being shared equally between the spouses
• the IRS proposed regulations on the issuance of membership units in exchange for services
• The new rules beginning in 2007 on taxation of LLC income, including separately stated items, charitable contributions, and Section 179 expenses
• The new 2007 Revenue Procedures on the elections that an LLC must make with respect to the domestic production activities deduction and qualified production activities income
• The new rulings and regulations issued in 2007 on reorganizations between LLCs, including mergers, reincorporations, drop-down of assets into a subsidiary LLC, transfer of assets to a parent organization, conversion from one type of entity to another
• The new IRS rulings regarding tax-free split-ups and spin-offs under Code Sec. 355 for corporations conducting business through an LLC
• the tax consequences of contingent liabilities in an LLC
• The 2007 IRS rulings on guaranteed payments, including the taxation of distributions of appreciated property to members as guaranteed payments
• The new IRS rulings regarding limitations on health plan deductions by members owning more than 2% of the membership interests in an LLC
• the use of an LLC in a like kind exchange, including distributions from an LLC to members immediately prior to a like-kind exchange
• the new rulings on minority and marketability discounts for Estate and gift tax purposes on transfers of membership interests in an LLC to family members
• The tax laws applicable to LLCs in all 50 states
• The charging orders, creditors’ rights, and asset protection for LLCs in the 50 states
• the statutory authority for series LLCs in the states in which such LLCs may be formed

Topics and Contents

Introduction

Summary of Llc Laws

Advantages and Disadvantages of Llcs

Special Issues Regarding S Corporations and Llcs

Classification of Llcs

Contributions

Taxation of Llc Income

Allocations

Basis and Member'S Share of Debt

Distributions

Reorganizations

Terminations

Loss Limitations

Payments and Benefits to Members

Transfer of Membership Interests

Self-Employment and Employment Taxes

Accounting Methods and Procedures

Foreign Llcs

Foreign-Owned Domestic Llcs

Investment Llcs

Estate and Gift Tax Planning

Federal and State Filing Requirements

State Tax Laws

Asset Protection, Charging Orders and Creditors