Feature Article 
Will Your Client’s LLC Operating Agreement Make an Election Under Subchapter S Invalid?
Organization of a business enterprise as a limited liability company (LLC) has a number of advantages. In addition to ease of formation, state LLC acts dispense with many of the formalities required for corporations and wide latitude is given to... Patrick D. Dimmitt
Fall 2024,
Feature Article,
§338(h)(10), Uniform Limited Liability Company Act, Form 1120-S, Subchapter S, ULLCA, safe harbor, Private Letter Ruling 201949009, §105(b), debt, Private Letter Ruling 201930023, Rev. Proc. 2022-19, limited liability company, Private Letter Ruling 202315005, §3.06, Private Letter Ruling 202110010, Corporate Governing Provision Statement, Form 8832, §704, §3.06(d), §1362(f), §83(b), s corporation, Treas. Reg. §1.704-1(b)(2), stock, Treas. Reg. §1.704-1(b)(2)(ii)(b)(2), employee, §1361(1)(D), Private Letter Ruling 202111011, election, Treasury Regulation §1.1361-1(l)(1), Private Letter Ruling 202310001, LLC
Capitol Corner
An Election Year Primer
As you read this, you are as near to the year 2000 as you were during the first year of the Reagan Administration. For some, the memory will be fond. For others, less so. For all, though, the reality is that while election cycles effectively start much earlier than they once did (Rona... Robert A. Kerr, EA