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BNA’s New Tax Portfolio Explores Investor Options for Disregarded Entities

NEWS RELEASE

Contacts:
Mark Carrington
(202) 530-1728

Washington, DC (February 20, 2007) – BNA®, publisher of the authoritative and universally recognized Tax Management Portfolios, has released the latest addition to the U.S. Income series. Portfolio No. 704, Disregarded Entities discusses the use of entities that have a separate legal status from their owners. The Portfolio explains how disregarded entities can be structured as a corporation (QSUB) or as a limited liability company (LLC).

Disregarded entities exist in three groups: 1) entities disregarded under the elective classification regime; 2) qualified S corporation subsidiaries; and 3) qualified real estate investment trust subsidiaries.  For each type, the Portfolio addresses the entity, qualification, formation, conversion, operation and termination issues. Disregarded Entities also explores the use of the entity in specific contexts including corporate reorganizations, partnership transactions, and like-kind exchanges. This Portfolio provides a list of key tax forms and primary document sources and preambles to relevant treasury regulations. Specific provisions such as the at-risk rules and the cancellation of indebtedness provisions are discussed. Use of disregarded entities in cross-border transactions and their impact on the direct and indirect foreign tax credit are also described.

This Portfolio may be cited as Abrams, Witt & Zarlenga, 704 T.M., Disregarded Entities.

Howard E. Abrams, Esq., is a former Director of Real Estate Tax Knowledge with Deloitte & Touche (1989-90) and served Of Counsel to Steptoe & Johnson (2003-04). He has been a Professor at Emory Law School since 1983; Adjunct Professor, University of Georgia College of Law, since 1993; and was a Visiting Professor, Cornell Law School (1987-88).  Abrams served as a Law Clerk to the Honorable Theodore Tannenwald, Jr., Chief Judge, United States Tax Court (1980-82). He has coauthored Federal Income Taxation of Corporations and Shareholders (Aspen Law & Business: 3d ed. 2000); Federal Corporate Taxation (Foundation Press: 5th ed. 2002); and Fundamentals of US Taxation (Kluwer Law International: 1999).  Abrams earned his B.A., University of California at Irvine (1976; summa cum laude); and a J.D., Harvard Law School (1980; cum laude). He is a member of the District of Columbia Bar; the American Law Institute; and the American Bar Association, Tax Section.

Fred T. Witt, Esq., is Principal, Deloitte Tax, LLP, Phoenix, Arizona, and coauthor of Collier on Bankruptcy Taxation (Matthew Bender 2001), part of the nationally recognized Collier on Bankruptcy 15th Edition.  From 1980-1982, Witt served as Attorney Advisor to Hon. Irene F. Scott of the United States Tax Court.   He earned a B.S. from Nebraska Wesleyan University (1976); a J.D. from University of Nebraska College of Law (1979); and an LL.M. (Taxation) from New York University (1980). Witt has served as a member of the American Bar Association Section of Taxation (Council, 2004-06; past Chair, Real Estate Committee, 1996-98); and is a member of the State Bar of Arizona.

Lisa M. Zarlenga, Esq., B.S., is a partner with Steptoe & Johnson LLP. in Washington, D.C. and a former Law Clerk to the Honorable Robert P. Ruwe, U.S. Tax Court (1994-96).  She earned a B.S. from Ohio State University (1991); a J.D., from Ohio State University College of Law (1994); and an LL.M. (Taxation) from Georgetown University Law Center (1997). Her memberships include the American Bar Association, Tax Section -- Corporate Tax Committee (Chairman of Subcommittee on Liquidations and Taxable Distributions), Government Relations Committee; 2004-2005, John S. Nolan Tax Law Fellow; District of Columbia Bar, Taxation Section -- Steering Committee (member), Corporate Tax Committee (Chairman), Federal Bar Association, Tax Section; the District of Columbia Bar and the State Bar of Ohio.

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About BNA®
BNA is the foremost publisher of print and electronic news, analysis, and reference products, including the recently launched Accounting Policy & Practice Series.  BNA publications intensely cover legal and regulatory developments for professionals in business and government. BNA is the oldest wholly employee-owned company in the United States, and produces more than 200 news and information services — including Daily Labor Report and Daily Tax Report — widely respected for comprehensive and objective reporting and analysis.

For more information about the BNA Tax Management Portfolios, call (800) 372.1033