August 1, 2021
The Mann Report published an article by Tax Partner Dennis Pellecchia and Tax Director Sean Burke, about achieving a 1031 exchange using Revenue Ruling 99-6 structure.
By Dennis Pellecchia, Partner, Tax & Business Services & Sean Burke, Tax & Business Services
Excerpt:
Revenue Ruling 99-6 covers transactions where a multi-member LLC becomes a single member LLC. The two scenarios where this accounting guidance comes into play are when one LLC member sells his or her full ownership interest to another member, making that remaining member the sole owner, or all LLC members sell their full ownership interests to a nonmember.
