Table of Contents

• REG-119921-09
  • AGENCY:
  • ACTION:
  • SUMMARY:
  • DATES:
  • ADDRESSES:
  • FOR FURTHER INFORMATION CONTACT:
  • SUPPLEMENTARY INFORMATION:
    • Background
    • 1. Introduction
    • 2. Entity Classification for Federal Tax Purposes
    • A. Regulatory framework
    • B. Separate entity classification
    • C. Insurance company classification
    • 3. Overview of Series LLC Statutes and Cell Company Statutes
    • A. Domestic statutes
    • B. Statutes with respect to insurance
    • Explanation of Provisions
    • 1. In General
    • 2. Classification of a Series that is Treated as a Separate Entity for Federal Tax Purposes
    • 3. Entity Status of Series Organizations
    • 4. Continuing Applicability of Tax Law Authority to Series
    • 5. Applicability to Organizations that Qualify as Insurance Companies
    • 6. Effect of Local Law Classification on Tax Collection
    • 7. Employment Tax and Employee Benefits Issues
    • A. In general
    • B. Employment tax
    • C. Employee benefits
    • 8. Statement Containing Identifying Information about Series
    • Proposed Effective Date
    • Special Analyses
    • Comments and Requests for a Public Hearing
  • Proposed Amendments to the Regulations
    • PART 301—PROCEDURE AND ADMINISTRATION
  • Drafting Information
• REG-144762-09
  • AGENCY:
  • ACTION:
  • SUMMARY:
  • DATES:
  • ADDRESSES:
  • FOR FURTHER INFORMATION CONTACT:
  • SUPPLEMENTARY INFORMATION:
    • Paperwork Reduction Act
    • Background and Explanation of Provisions
    • Special Analyses
    • Comments and Public Hearing
  • Proposed Amendment to the Regulations
    • PART 1—INCOME TAXES
  • Drafting Information
• Announcement 2010-80
• Announcement 2010-81