Saturday, April 23, 2005
Stephanie R. Hoffer (NYU Tax LL.M. 2005) has published Give Them My Regards: A Proposal for Applying the COD Rules to Disregarded Entities, 107 Tax Notes 327 (2005), also available on the Tax Analysts web page as Doc 2005-5259, 2005 TNT 74-50. Here is the abstract:
This article discusses application of the COD rules to disregarded entities and concludes that the IRS should regard disregarded entities for that purpose. Hoffer argues that to do otherwise would not only engender uncertainty in lending transactions with single-member LLCs but would also distort the federal tax system's comprehension of underlying state law business arrangements.