On September 14, 2010, the U.S. Internal Revenue Service (IRS) published proposed regulations that address the tax entity classification status of a series of (i) a domestic series limited liability company (LLC), series partnership, series trust, protected cell company (PCC), segregated cell company, segregated portfolio company or segregated account company and (ii) a foreign series or cell company that conducts an insurance business. The proposed regulations generally provide that each series will be treated as a separate entity for income tax purposes. These rules are not yet in effect, but when final will apply to all domestic and certain foreign series organizations, except for certain entities formed prior to September 14, 2010.
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