single-owner DREs (e.g., SMLLCs) as corporations for employment tax purposes. 24 Thus, the entity now must use its own taxpayer identification number when it files and pays employment taxes. 78 An individual owner of a DRE, however, is subject to self-employment tax and is not treated as an employee of the disregarded entity for employment tax purposes. “2 This special employment tax provision is applicable with respect to wages paid on or after 1/1/09. 2° The IRS also recently updated its Employer Tax Guide to reflect the final regulations. 2* In addition, the IRS issued a similar provision with respect to certain excise tax reporting, registration, and payment obligations. 24 That provision treats an eligible single-owner DRE as a separate entity for certain excise tax purposes. ** This special excise tax rule applies to liabilities imposed and actions first required or permitted in periods beginning on or after 1/1/08. ** The IRS also issued a final regulation under Section 1361 that mirrors the employment and excise tax regulation provisions promulgated under Section 7701. = Like the check-the-box regulations’ rules, the QSub regulation treats a QSub as a corporation for employment and excise tax purposes only. 22 The regulation relating to employment taxes applies with respect to wages paid on or after 1/1/09, but the excise tax provision applies to liabilities imposed and actions first required or permitted in periods beginning on or after 1/1/08. #4 The IRS probably did not need to issue separate provisions under Section 1361 because Regs. 301.7701- 2(c)(2){iv) and (v) appear to cover QSubs as well as SMLLCs. The IRS did not issue special provisions with respect to REITs, but Regs. 301.7701-2(c)(2)(iv) and (v) should also cover REITs. There is no authority explicitly extending these rules to grantor trusts. Tax Liability Considerations A DRE, including an SMLLC, a QSub, and a QRS, is treated as a separate entity for purposes of: (1) Federal tax liabilities of