Partnership and LLC Taxation

Incorporating a Partnership or LLC: Does Rev. Rul. 84-111 Need Updating?

Taxpayers’ widespread adoption of the limited liability company (LLC) has caused Treasury and the IRS to take a closer look at transactions using it. For example, most states’ enactment of rules allowing for mergers involving LLCs was one reason Treasury issued Regs. Sec. 1.368-2(b), to address statutory mergers involving disregarded
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