Ezel / IRS Rulings / 201013043

CCA 201013043: IRS comments on language for single-member LLCs

Number
201013043
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definitions
Topics
Entity classification
Code sections
§ 7701, § 6110
Ruling dated
February 26, 2010
Publicly released
April 2, 2010
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2010, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2010
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advice addressed language concerning single-member limited liability companies. It stated that the pre-change language may have been accurate based on when services were performed. The advice deferred a conclusion about whether the current language was sufficient to another IRS employee.

Ruling snapshot

  • Question: Was the earlier language concerning single-member LLCs accurate, and is the current language sufficient?
  • Outcome: Advice given
  • Key authorities: IRC § 7701

Full text (IRS public release)

ID: CCA_2010022617272641 Number: 201013043
Release Date: 4/2/2010
Office: -----------------------------
UILC: 7701.00-00

From: ---------------
Sent: Friday, February 26, 2010 5:27:27 PM
To: ---------------
Cc:
Subject: RE: Single member LLCs

In that case, the pre-change language may have been accurate based on when services were
performed. I'll have ---------respond to you on whether your current language is sufficient.

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