Comments on: Real estate holding structures for nonresidents – tax law changes coming

By: Subscribe to My Emails

Subscribe to My Emails — Mon, 27 Jul 2009 18:14:54 +0000

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By: admin

admin — Mon, 27 Jul 2009 17:25:20 +0000

@Dale

I don’t know what will work at this point. If a pass-through is needed, we may have to go back to the overly-complex situation of creating partnerships. There is usually a non-tax reason for the disregarded entity (liability shield, administrative convenience, enhanced privacy), and it may well be worth setting up limited partnerships with a special purpose C corp as the general partner.

By: admin

admin — Mon, 27 Jul 2009 17:23:27 +0000

@roger

Yes I think the disregarded entity thing will be looked at by the IRS. Too bad. It is a useful tool — a liability shield with minimized paperwork.

Phil

By: Roger

Roger — Thu, 23 Jul 2009 15:38:57 +0000

I think this change is just the beginning of alot more changes coming in the way of disregarded entities. I’ve noticed there is a lot of single member LLC holders in real estate, especially in CA and FL.

Let’s see what happens!

By: Dale W Bender

Dale W Bender — Wed, 22 Jul 2009 19:08:39 +0000

What changes are you suggesting to the ((… wedding cake of trusts, corporations, partnerships, and limited liability companies that you pay for every year) and plan to change those structures before the end of 2010.)? I only can think of eliminating the disregarded entity concept at this time. What do you suggest?