Posted: May 04, 2005 By: Tracy Hollingsworth

Subject: Unify Partnership & Sub S Taxation

Comment: Virginia has unified its taxation of pass through entities. This presents some problems related to the extra-Virginia reach of the provisions. Taken to the federal level, this sort of approach could greatly simplify the tax law by eliminating or reducing the number of regimes governing pass-through entities. Just eliminating the Sub S regime (with transition rules) would be a major step; the rise of LLCs and LLPs makes the Sub S regime unnecessary except for those who use it to reduce employment taxes and those who are locked into a Sub S because it can be expensive to unwind.