Author: fbretax

I thought I would share some new concepts I learned. LLC as a Contractual Arrangement So numerous cases have cited LLCs as “creatures of contract.” One case described that contract as occurring between the members, the managers, and the LLC. Clary v. Borrell. Furthermore, this contract between members, sometimes referred to as an operating agreement, […]

It makes sense to define real property for tax purposes when discussing real estate tax. Under 1.856-10, real property is actually defined as land and improvements to land. Local law is not controlling. Although this is for Subchapter M, this is relatively consistent with the regs of 48, which states that real property is property […]

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