regulations have allowed the IRS to ignore intermediate entities participating in a
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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
the DRE's obligations are taken into account when
the rules provide a general assumption that a partner is financially able to perform
partnership debt is generally allocated to the
which deal with the allocation of partner-level tax basis arising from
was an indirect partner via the “pass-thru partner”).