Give Them My Regards: A Proposal for Applying the Cod Rules to Disregarded Entities
Posted: 18 Apr 2005
This article discusses application of the COD rules to disregarded entities and concludes that the IRS should regard disregarded entities for that purpose. Hoffer argues that to do otherwise would not only engender uncertainty in lending transactions with single-member LLCs but would also distort the federal tax system's comprehension of underlying state law business arrangements.
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