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QUESTIONS & ANSWERS

Emerging Issues and Insights

Q. If an LLC owns two single-member LLC subsidiaries, can an LLC member use a positive at-risk amount from one of the LLC subsidiaries to provide an amount at risk for an “unsupported” loss of the other LLC subsidiary?

A.

Potentially yes, under the §465(c)(3)(B) aggregation rules. The two activities must constitute a “trade or business” and at least 65% of the losses must be allocated to “active” participants. Note that box 22 of the K-1 must be checked when there is “more than one activity for at-risk purposes,” and the LLC is required to attach a separate statement to the K-1 containing information as to the income, expenses, and other items for each activity.

None of the authors is rendering legal, accounting or other professional advice. If such advice is required, it is strongly recommended that a professional advisor be engaged.

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