Client Alert: U.S. Treasury Regulation Changes Could Impact Foreign Owned Single Member LLCs.
Insight Melinda Fellner Bramwit · May 23, 2017
Changes to US Treasury Regulations Under Section 6038 of the Internal Revenue Code could affect filings for single member LLCs owned by non-US persons.
Many non-resident individuals and non-resident entities maintain title to real estate and other assets in single member limited liability companies incorporated under state law in the United States, for a variety of reasons. Under Federal tax law, such an entity is disregarded for tax purposes unless the owner elects otherwise. From a corporate perspective, these limited liability companies can be used to harness assets in an entity separate from the owner, providing a layer of corporate protection and perhaps anonymity for the ultimate owner. These entities are also reasonably simple to form and maintain.
Melinda represents clients in federal, state and international tax issues in both planning and transactional matters. Her work includes business structuring, mergers, acquisitions and reorganizations, as well as structuring joint ventures and partnerships and assisting in drafting operating agreements.
In addition to her transactions representations, Ms. Fellner Bramwit represents individuals in tax and estate planning, including such matters as transfers of start-ups and family businesses. She has been particularly active in offering planning advice to physicians and their practices.
Read Ms. Bramwit complete background