Prior to the issuance of these regulations, the entity classification election regulations would have treated this type of entity as disregarded
from its owner (other than for employment and excise taxes) unless an election was made to treat it as a corporation for U.
entities are in some respects very similar to pass-through entities.
Further disability-related leave was disregarded
but, following a shoulder injury sustained by the employee, a further formal meeting was held and the employee was dismissed.
Swiftly, and with very little analysis, the court determined "the claim that the arbitrator disregarded
the law, [is] not included among those specifically enumerated in [section] 10 and [is] therefore not cognizable.
Formerly, a noncorporate entity with a single owner was disregarded
as a separate entity for most federal purposes, including exemption from federal employment tax reporting.
7701-2-(c)(iv)(B), which provides that a disregarded
entity will, instead of being disregarded
, be treated as a corporation with respect to employment tax obligations.
He initially explained that this was not a situation in which the arbitrator disregarded
the parties' choice of law in favor of alternative law, or no law at all.
The partnership or S corp has changed, or will change, its tax year because its current year no longer qualifies as a natural business year or the S corp's current year no longer qualifies as an ownership tax year because a tax-exempt owner is disregarded
The IRS recently issued Notice 99-6, soliciting comments from and providing guidance to taxpayers and practitioners regarding issues related to employment tax reporting and payment by qualified subchapter S subsidiaries (QSSS) and other entities that are disregarded
as separate from their owners, i.
According to the complaint, the true facts, which were known or recklessly disregarded
by the defendants but concealed from the investing public during the Class Period, were as follows: (a) the Defendants knew or recklessly disregarded
material adverse information about the Company's financial results and then existing business condition; and, as a result, the Company's projections and reported results were based upon defective assumptions and/or manipulated facts; and (b) the Company's financial statements were materially misstated due to the fact that PainCare failed to properly account for expenses and consistently overstated earnings.
entities wholly owned by foreign persons are now subject to new reporting obligations.
Under Nebraska law the factors relevant to determining whether a corporation is, or becomes, a person's alter ego such that the corporate form should be disregarded
include (i) diversion by the shareholder of corporate funds or assets to their own or improper uses and the fact the corporation is a mere facade for the shareholder's personal dealings and the corporation's operations are carried on by the shareholder in disregard of the corporate entity; and (ii) the absence of corporate formalities, the commingling of corporate and personal funds and expenses and the family relationship between corporate officers and the taxpayer.