Thomas E. Rutledge (Stoll Keenon Ogden, Louisville, KY) has posted Regarding the Disregarded Entity, 12 J. Passthrough Entities 55 (Mar.-Apr. 2011). Here is the abstract:
The “disregarded entity” is often described as a “tax nothing,” an entity not only transparent to, but actually outside the contemplation of, the tax code. Problems arise, however, when the hybrid nature of the tax nothing LLC is not fully considered – while the structure may be ignored for purposes of federal taxation it can and often does impact upon matters governed by state law.
