Series LLC's Get Tax Break
Michael Stoop+“Series” limited liability companies may become more prevelant now that the IRS has proposed regulations on their classification for tax purposes. A series LLC is a master LLC with different groups of interests. For example, a manufacturer with retail stores could put the retail operations into one series and the manufacturing business into another. Harley Davidson is a perfect example of such an entity. Although they are known as a motorcycle manufacturer , almost 12 % of their revenue is derived from merchandising sales. Companies like Harley Davidson like to break out their retail operation from their manufacturing operation predominately due to a significant break in their workers compensation insurance costs. Without having a separate LLC all of their clerical store employees fall under the highest class code of their manufacturing operation which contributes significant workers compensation costs.
Under state law, creditors of the retail series could not reach the other’s assets. Series LLCs are allowed by Del., Ill., Iowa, Nev., Okla., Puerto Rico, Tenn., Texas and Utah.
Each series is a separate entity for federal tax purposes, the IRS says, except that series organizations up and running before Sept. 14, 2010 may be treated as a single entity.
If you have an operation that is diverse with a large disparity in the premium for Workers Compensation Premium we would encourage you to ask your accountant and insurance advisor about setting up a "Series LLC".

