Archive - September 2010
Series LLC - Prop. Reg. 301.7701-1(a)(5) September 20, 2010
Series LLC, a relatively new structure, is available to U.S. funds who are seeking flexibility. This form was first introduced in Delaware and later was adopted by several other states including Illinois. The key highlight of the structure is that for state law purposes the LLC is a single entity, while for federal income tax law, each series of the LLC, purportedly, is treated as a separate entity. The apparent advantage of this set up is flexibility and reduction of organization and administrative cost. Separate series could be established for each portfolio company or each class...