Infographic: Navigating IRS revenue rulings on reorganizations

10/25/2022
Infographic: Navigating IRS Revenue Rulings on reorganizations

Uncover the differences between two IRS revenue rulings that treat LLCs targeted for acquisition as disregarded entities for federal income tax purposes. 

Implications of IRS Revenue Ruling 99-5 on reorganizations
Implications of IRS Revenue Ruling 99-6 on reorganizations
Implications of IRS Revenue Ruling 99-5 on reorganizations
Implications of IRS Revenue Ruling 99-6 on reorganizations

Implications of IRS Revenue Ruling 99-5 on reorganizations 

IRS Revenue Ruling 99-5 lays out guidance for two situations in which an LLC targeted for acquisition is treated as a disregarded entity – and separate from the organization that owns it – for federal income tax purposes. Let’s explore how each scenario plays out. 

Implications of IRS Revenue Ruling 99-6 on reorganizations 

IRS Revenue Ruling 99-6 provides guidance on acquisitions involving multimember LLC targets, which convert to disregarded entities as a result of a purchase. Let’s examine the steps involved in this process. 

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Katie Mishler
Katie Mishler
Partner, Tax
Michael Schindler
Michael Schindler
Principal, Washington National Tax