Every indexed document

generally treat a DRE as a separate entity. 73 An example of a DRE to

and the consolidated return regulations that

for purposes of the regulations under Section 881

any transaction entered into by a DRE will be taken into account for

the IRS issued proposed regulations under Section 881. 69 Under Prop. Reg.

regulations have allowed the IRS to ignore intermediate entities participating in a

the advance and receipt are effected through one or more other persons

a wholly grantor trust is treated as a separate entity for

even though the distinction may be disregarded for federal and state

because for sales tax purposes New York generally respects the separate existence

unless the grantor trust is a revocable trust. 63 For

Pennsylvania varies from federal law regarding grantor

states may not disregard a wholly grantor

62 the Second Circuit Court of Appeals implicitly held that a

opinions differ as to whether a wholly grantor trust is considered a

many states allow an SMLLC and its owner to

notwithstanding the fact that for state income tax purposes

most states require an SMLLC to file its own

before proceeding with planning opportunities in that state.

several states impose an entity-level tax or fee on LLCs