Proposed Regulations on Series LLCs Provide ‘Base Rule'

For over 50 years, Bloomberg BNA’s renowned flagship daily news service, Daily Tax Report® has helped leading practitioners and policymakers stay on the cutting edge of taxation and...

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.”