Married taxpayers who wholly own an LLC in a community property state will not have to file a partnership return if the business is a qualified entity
and they treat it as a disregarded entity.
* The qualified entity
would pay a fee that covers CMS' cost of making the data available.
2010-32 are met, the IRS will respect the intention of a qualified entity
(defined below) to be treated as a flowthrough entity (i.e., as a partnership or disregarded as an entity separate from its owner (a disregarded entity)) rather than treat the qualified entity
as an association taxable as a corporation.
Prior to the enactment of IRC section 761(f), husband-and-wife businesses (excluding mere co-owners) were required to file a partnership return pursuant to IRC section 6031 (a), unless they could elect out of partnership classification under IRC section 761(a), or unless the business was a "qualified entity
" that consisted solely of community property owned by both spouses, as provided in Revenue Procedure 2002-69.
A qualified entity
is a business entity that is wholly owned by a husband and wife as community property under the laws of a state, foreign country or U.S.
UAV Airways is a UK CAA Approved National Qualified Entity
that provides UAV training, including qualifying future UAV pilots.
In this case, there is no qualified entity
on the acquiring side of the transaction.