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Archive for the ‘Limited liability companies’ Category

Steve Looney Speaks at 60th Annual William & Mary Tax Conference

Published: November 12th, 2014

By: Stephen R. Looney

Steve Looney, shareholder and chair of Dean Mead’s Tax Department spoke at the 60th Annual William & Mary Tax Conference in Williamsburg, VA, on November 7, 2014. He presented on “Reclassification Risks For Compensation Paid by S and C Corporations to Shareholder-Employees“. In addition to covering unreasonably high compensation in the “C” corporation context and unreasonably […]

Steve Looney Speaks at 63rd Tulane Tax Institute in New Orleans

Published: October 24th, 2014

By: Stephen R. Looney

Stephen R. Looney, Chair of Dean Mead’s Tax department, was a guest speaker at the 63rd Annual Tulane Tax Institute in New Orleans, LA on October 22, 2014. His presentation was titled, “Reclassification of Compensation Paid by C Corporations and Reclassification of Distributions Made by Corporations to their Shareholder-Employees”. Mr. Looney discussed how the IRS and […]

IRS Rules That Members of LLC Are Not “Limited Partners” for Purposes of Avoiding Self-Employment Tax

Published: September 24th, 2014

By: Stephen R. Looney

  In ILM 201436049 (9/5/2014), the IRS found that members of a management company LLC (“Management Company”) were not “limited partners” within the meaning of Section 1402(a)(13) and therefore were subject to the self-employment tax on their distributive shares of income of the Management Company.   Under the facts of the ruling, a limited liability […]

Can a Partner of a Partnership or a Member of a LLC Be treated as an Employee?

Published: August 21st, 2014

By: Stephen R. Looney

  On 6/13/2014, Curtis Wilson, IRS Associate Chief Counsel (Passthroughs and Special Industries) stated that he is concerned about the rumored use of a disregarded entity to enable a partner to be treated as an employee for withholding purposes.[1]  Under the purported structure, a partnership creates a wholly-owned entity that is disregarded for federal income […]

What You Should Know about the New Limited Liability Company Act

The Florida legislature passed Senate Bill 1300 in the 2013 session, which created a Revised Limited Liability Company Act in Florida as a new Chapter 605 of the Florida Statutes (the current LLC Act is in Chapter 608). All LLCs formed in 2014 are subject to the new LLC Act upon formation. Until January 1, […]

Steve Looney Speaks at University of Texas 61st Annual Taxation Conference

Published: December 6th, 2013

Dean Mead attorney Stephen Looney was a featured speaker at the University of Texas 61st Annual Taxation Conference held in Austin, Texas on December 5th, 2013.  Mr. Looney’s presentation was entitled “Compensation Reclassification Risks for S and C Corporations.”  The presentation discussed how the IRS and the Courts are addressing the reclassification of compensation and other payments […]

Stephen Looney Speaks at NYU Tax Institute

Published: November 22nd, 2013

By: Stephen R. Looney

Dean Mead attorney Stephen Looney was a featured speaker at the 72nd NYU Tax Institute in San Francisco, California on November 20th, 2013.  Mr. Looney’s presentation was entitled Tax Effects of Converting Entities Under Check the Box, State Law Conversion Statutes, State Law Merger Statutes and “Manual” Conversions.  The presentation examined the federal tax consequences of changing […]

Members of Diagnostic Imaging LLC Subject to Self-Employment Taxes

Published: November 22nd, 2013

By: Stephen R. Looney

In Reither v. Commissioner, 112 AFTR2d 2013-6074 (D. N.M.), the court rejected on summary judgment a radiologist’s and his wife’s claim that they were not liable for self-employment tax on their distributive share of income from a diagnostic imaging LLC taxed as a partnership.  Although not clear from the facts of the case, presumably all […]