This article summarizes rules relating to entities that may be "disregarded
" for purposes of Section 1031 and is designed to assist in cases where a taxpayer would like to take title to the replacement property in a manner that is different from the manner in which they held title to the relinquished property.
1.752-2(k) provides that in determining the extent to which a partner who owns an interest through a disregarded
entity bears the economic risk of loss for a partnership recourse liability, payment obligations of the disregarded
entity (including a disregarded
SMLLC) are taken into account under Sec.
"As long as everyone knows how many K-1s have been issued and everybody knows that there is a disregarded
entity and that it only has one individual that owns it, there is no justification for not granting an exemption" to the partnership to elect out, he said.
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." (35)
BEIRUT: Future Movement MP Mohammad Qabbani accused the government of Prime Minister Najib Mikati of ignoring the role of the Parliament Tuesday, saying that lawmakers will no longer tolerate being disregarded
by the Cabinet.
The IRS asserted that, since the LLC was a disregarded
entity, it also should be disregarded
for federal gift tax valuation purposes.
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.
[section] 301.7701-2-(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.
When libertarian-oriented activist judges such as Fields and Peckham disregarded
an objective reading of the Constitution in order to elevate their personal beliefs to the highest law of the land, they set the stage for FDR-appointed activist judges to disregard the objective meaning of the Constitution (e.g., the Commerce Clause) in order to uphold outrageously unconstitutional legislation.