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In IRS Proposal, an Attempt to Tackle Growing Use of LLC Loophole

By Valentina Pasquali

A proposed reporting requirement for foreign-owned legal entities would impact a small but growing universe of companies that have likely been used to funnel illicit funds into the United States, say legal experts. Earlier this month, White House officials disclosed draft regulations that would require so-called "disregarded" foreign-owned entities to obtain employer identification numbers, or EINs, from the IRS and disclose their addresses and the names of executors, administrators and "responsible parties," among other information. The entities would thereafter be obligated to inform the IRS of "reportable transactions between the entity and its foreign owner or other foreign-related parties"-data the...

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