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LLC - H&W divorce

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    LLC - H&W divorce

    Husband & wife operate a LLC which is taxed on Sch. C as they live in a community property state (WI). They are getting a divorce. As part of the divorce settlement, the husband will own the business 100%.

    1. Since there will be a 50% change in ownership, is there any tax event? (My understanding is the changing the ownership of the business will be effected this year, while the divorce will be final January 2008.) They will still be filing a MFJ return for 2007. Generally 50% changes terminates a partnership, but since this isn't being taxed as a partnership does it matter?

    2. Husband is considering changing the name of the business or starting new LLC. Will this impact answer to #1?

    3. Most of the fixed assets are fully depreciated by Sec. 179 in prior years. If husband renames the business or creates new business, how are the fixed assets handled? My thought is since fully depreciated, you can't depreciate again. And no gain or loss on termination of previous business.

    Am I missing anything?

    #2
    Since they did not file a 1065, it is as if it is a disregarded entity for federal tax purposes, meaning it is a Schedule C. The 50% change of ownership rules for partnerships do not apply.

    As to transfering ownership between spouses, there is no tax consequence of doing so when it is between spouses, or between ex-spouses due to a divorce [IRC ยง1041].

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      #3
      Great. That's what I thought but wanted confirmation.

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