EFTA01106843

Office of Chief Counsel Internal Revenue Service memorandum Number: 201343021 Release Date: 10/25/2013 CC:PSI:B02:WMKostak POSTF-105947-12 Third Party Communication: None Date of Communication: Not Applicable UILC: 165.00-00, 267.01-00, 671.00-00, 707.02-01 date: June 17, 2013 to: Associate Area Counsel CC:SB:4CH1:1 (Small Business/Self-Employed) from: Senior Counsel CC:PSI:02 (Passthroughs & Special Industries) subject: Application of Grantor Trust Rules and Ownership Attribution Rules of §§ 267 and 707(b)(1)(A) This Chief Counsel Advice responds to your request for assistance. This advice may not be used or cited as precedent. LEGEND LLC = A= B= C= D= E= F= M= N= O= X= Y= Z= EFTA01106843