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A number of questions regarding series LLC ownership issues have come up following the release of proposed regulations (REG-119921-09) on the treatment of domestic cell companies and foreign companies conducting insurance business, IRS officials say. Speaking at a D.C. Bar luncheon, Dianna Miosi of the IRS Office of Associate Chief Counsel (passthroughs and special industries) says the proposed regulations “provide one very straightforward rule: the series is going to be treated as an entity formed under local law.”
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