On November 25, 2011 the Treasury Department issued proposed regulations relating to the definition of an "interest in a limited partnership as a limited partner". Specifically, the proposed regulations address the situations wherein a member of an LLC will be treated as not owning an interest in a limited partnership as a limited partner under Treas. Reg. 1.469-59(e)(3).

Under the proposed regulations, an individual is treated as owning an interest in a limited partnership as…

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