HOUSE_OVERSIGHT_026584.txt

The article discusses disregarded entities and their treatment for tax purposes. It highlights the exceptions to the general rule that a disregarded entity is treated as a "tax nothing" and outlines some of the more significant modifications to this rule. The authors provide an overview of four types of DREs, including grantor trusts, single-member LLCs, qualified subchapter S subsidiaries, and controlled foreign corporations, and their legislative origins. Practitioners are advised to be attentive to these growing exceptions and modifications when planning for their clients.