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Taxation of the Limited Liability Company (LLC) One benefit of the use of  limited liability company is the flexibility of being able to choose how the entity is taxed. There are many factors to consider when deciding to have your LLC taxed.  Your choice should be based on your own specific situation. Therefore, before making any decisions on your form of business, you should speak with us.  The single-member LLC provides corporate-level liability protection for the business owner along with taxation as a sole proprietorship.  Contact Us for Assistance

Single Member LLC (SMLLC) By default, an LLC is treated as a pass-through entity, which means that it does not pay U.S. tax directly, but its income or loss is allocated to the owners, who then pay taxes on that income.  If the LLC has one member, it files no tax return and the transactions of the LLC are treated as transactions of the owner for tax purposes.  A single member LLC is treated as though it does not exist for tax purposes and thus the owner is treated as if he were running a sole proprietorship.  All transactions (income and expenses) are included on the owner's U.S. tax return.  The owner of a SMLLC pays self-employment taxes on Schedule C income, just like a sole proprietorship. The SMLLC can elect to be tax as a regular corporation or as an S corporation (read below).

SMLLC Benefits Federal law currently taxes the single-member LLC as a proprietorship for both income and family employment tax purposes. Example.  Say you set up a new single-member LLC to conduct what was previously your sole proprietorship business.  As far as the IRS is concerned, nothing has changed; the IRS ignores the existence of your single-member LLC (it's disregarded) and continues to consider your business a sole proprietorship for federal tax purposes.  Therefore, you report your business income and expenses on Schedule C, compute your self-employment tax on Schedule SE, and make quarterly estimated tax payments as usual.  The second benefit to the single-member LLC is the ability to use proprietorship (Schedule C) tax breaks, such as hiring your spouse to create a business tax deduction for a Section 105 medical reimbursement plan that pays the family medical expenses (health insurance, co-pays, out-of-pocket, and more); hiring your children without payroll taxes because they are under age 18 and working for a parent (disregarded entity); deducting interest paid on car loans;avoiding the cost of extra tax returns; and avoiding unexpected tax problems caused by self-dealing (although to ensure legal protection, you should avoid self-dealing).

Multi Member LLC (MMLLC) If the LLC has more than one member, the LLC can opt for treatment as a partnership for U.S. tax purposes.  Income and losses of the LLC are allocated to the owners, who pay taxes on that income regardless of the amount of cash they received from the company.   A distribution of cash to owners is itself a tax-free event.  The owners of the LLC can be compensated for service to the company (called "guaranteed payments") in which case the payments are treated as an expense to the partnership and income to the owner.  Subchapter K is quite flexible, and allows the owners to allocate the income between themselves in a variety of ways, sometimes in quite complex formulas (subject to certain limited restrictions in the Internal Revenue Code).  When using a partnership tax approach,  the income of the partners is generally subject to the self-employment tax.

Corporate Tax Option The owner(s) of an LLC, whether the LLC has a single member or multiple members, may choose to have their LLC taxed as a corporation.  In this case, the LLC can be taxed as a C Corporation (or, if the owners are U.S. persons, an S Corporation).  The ability of LLC owners to elect the LLC's method is called "checking the box" via filing Form 8832.  If an LLC elects to be taxed as a regular ("C") corporation, it is treated for tax purposes, as if it were a corporation.  The company must file a corporate tax return (regardless of whether there is one member or multiple members) and the LLC itself pays taxes.  Any income that is paid to owners in the form of dividends is also taxable income to the owner (resulting in double taxation), though taxed to the owner at the capital gains rate.  An C Corporation pays FICA, Medicare, and unemployment taxes on wages paid to the owner. The owner-employee pays FICA and Medicare on the owner's wages.  Active owners are considered employees of the company and can also be paid for their services to the LLC in the form of a salary or other payments.  In that case, the payment is deductible.  Note that wages paid to an under-age-18 child are subject to FICA, Medicare, and unemployment taxes. 

Unlike an S Corporation (see below), a C Corporation is allowed good tax breaks, such as hiring your spouse to create a business tax deduction for a Section 105 medical reimbursement plan that pays the family medical expenses (health insurance, co-pays, out-of-pocket, and more).  A deduction is allowed for the cost of a disability insurance for an owner (if the benefits are taxable to the owner) and Section 179 expensing.  As a result of the exposure to double taxation, many C Corporation owners pay themselves a salary or bonus.  Such income is deductible to the corporation, as long as it is "reasonable."  If the IRS determines otherwise, it can reclassify part of the salary as a constructive dividend and charge the company additional tax (and assert penalties).

S Corporation Tax for U.S. Persons Only If an LLC elects Subchapter S, it is treated for federal tax purposes, as if it were a corporation that elected to be treated as an S Corporation. Many form S corporations with no idea of the bottom-line results.  In this case, the LLC files a corporate tax return but does not itself pay taxes.  The income flows through to the individual level (caution: some states assess a corporate tax on the S corporation).  Each owner is allocated a portion of profits or losses based on the percentage interest that they each own.  As in a partnership, the owners must then pay the taxes themselves, regardless of whether any cash has been distributed to them.  Any cash payments to owners (called distributions or dividends) are tax-free.  An S Corporation pays FICA, Medicare, and unemployment taxes on wages paid to the owner.  The owner-employee pays FICA and Medicare on the owner's wages.  Active owners are considered employees of the company and can also be paid for their services to the LLC in the form of a salary or other payments.  In that case, the payment is deductible.  Note that wages paid to an under-age-18 child are subject to FICA, Medicare, and unemployment taxes.

S Corporation Cautions The benefit of S Corporation status is that income that is not paid out as a salary is not subject to self-employment taxes.  However, the IRS scrutinizes the salaries paid to owners and may decide that the owners are underpaid.  If it does, the IRS may reclassify some of the LLC's income as wages, subjecting the LLC and the owners to additional payroll taxes and potential penalties.  Another caution to use of S Corporations is the limited ability to use proprietorship (Schedule C) tax breaks, such as hiring your spouse to create a business tax deduction for a Section 105 medical reimbursement plan that pays the family medical expenses (health insurance, co-pays, out-of-pocket, and more).  You cannot make a Section 105 medical reimbursement plan available to more than 2% owners or their spouses.  While no deduction is allowed for the cost of a disability insurance for an owner, the benefits are not taxed to the owner.  Section 179 expensing flows through to the individual level.   Another disadvantage to using Subchapter S is that the designation is conditional.  There are a number of requirements the company must adhere to (such as having only one class of stock).  If the company fails to adhere to these requirements, it will automatically be converted to C Corporation status and face double taxation.   The single class of stock requirement is especially easy to violate inadvertently.  If the LLC gives any owners preferred distributions or distributes distributions in any way except through a straight pro rata method, it could be deemed as having more than one class of stock.  In addition, many of the default provisions in LLC statutes violate the single class of stock requirement, which means that the operating agreement of an LLC taxed under Subchapter S must be carefully written to override the default provisions.

Conclusion You are unlikely to identify a business entity that has all advantages for you and no disadvantages.

Offshore Unrelated Business Taxable Income (UBTI) Blocker Companies Many hedge funds use corporations as unrelated business taxable income (UBTI) blockers for their investors to facilitate hedge fund investment.  UBTI blocker companies are used to prevent U.S. tax-exempt organizations from recognizing UBTI and to prevent foreign investors from recognizing income that is effectively connected to a U.S. trade or business, and therefore taxable in the United States.  Hannah Terhune, a leading tax attorney, can help you with international tax planning and has published many international tax articles of interest to hedge fund managers.  Contact Us

U.S. Tax Exempt Investors One reason to setup an offshore fund is so the fund can accept U.S. tax-exempt investors.  Under the U.S. income tax laws, a tax exempt organization (such as an ERISA plan, a foundation, an endowment, etc.) engaging in an investment strategy that involves borrowing money (margin) is liable for a tax on “unrelated business taxable income” (UBTI).  This is true even though the investor is otherwise tax exempt.

As U.S. funds are formed through pass-through entities (such as the limited partnership or limited liability company) the UBTI activity passes through the fund to the tax exempt investor, thereby creating the UBTI tax issue.  U.S. taxable investors don't care because they need to pay tax in any event.   However, U.S. tax-exempt investors are quite concerned.  The UBTI tax can be avoided by arranging for the tax-exempt entity to invest in an offshore fund formed as a corporation.  The UBTI gets blocked, so to speak, at the wall of the corporation.

This is not an easy tax issue to grasp.  UBTI is income from regularly carrying on a trade or business that is not substantially related to the organization's exempt purpose.  UBTI excludes various types of income such as dividends, interest, royalties, rents from real property (and incidental rent from personal property), and gains from the disposition of capital assets unless the income is from debt-financed property. Using margin to trade creates debt financed property.   As a fund's income attributable to the use of margin may constitute UBTI to them, tax-exempt investors generally refrain from investing in funds classified as partnerships using leveraged trading strategies.   As a result, fund sponsors organize separate offshore funds for tax-exempt investors.

Offshore Unrelated Business Taxable Income (UBTI) Blocker Companies Many hedge funds use corporations as unrelated business taxable income (UBTI) blockers for their investors to facilitate hedge fund investment.  UBTI blocker companies are used to prevent U.S. tax-exempt organizations from recognizing UBTI and to prevent foreign investors from recognizing income that is effectively connected to a U.S. trade or business, and therefore taxable in the United States.  Hannah Terhune, a leading tax attorney, can help you with international tax planning and has published many international tax articles of interest to hedge fund managers.  Contact Us

International Taxes Hedge funds should be aware of possible international filings if either they own an interest in a foreign entity or have an investor who is a non-U.S. taxpayer.  Non-compliance with international tax filings could result in significant penalties.  For example, a penalty for late filing of a return could be as high as 25% of the unpaid tax.
 
Foreign Account Tax Compliance Act, or FATCA FATCA requires foreign financial institutions (FFI) and U.S. holding agents to track U.S. account holders.  Basically, foreign banks, brokers, custodians and offshore hedge funds--all are classified as an FFI.  Under FATCA, FFIs are required to disclose details about their U.S. and certain foreign clients to the IRS annually.  Offshore hedge funds have to collect, verify, manage U.S. account holder tax data, and be able to handle U.S. tax reporting and withholding responsibilities by 2017.  Any U.S. individual or entity unwilling to provide the required information faces 30% tax on amounts that are deemed attributable to its share of the underlying income and gross proceeds from the fund’s direct and indirect U.S. assets.  For offshore hedge funds, this rule starts in 2017.

International Traders Many international traders own U.S.-brokerage accounts and wonder if they will owe U.S. taxes.  When a nonresident trader has a U.S. brokerage account, only interest and dividends earnings are subject to U.S. withholding tax.  No U.S. withholding tax should apply to capital gains.  Many brokerages will withhold taxes anyway.  Nonresidents (individual or business) can file for a tax refund using a Form 1040NR and then properly structure their U.S. focused trading to prevent mistakes in the future.  In most cases, U.S. tax liability does not arise. However, ownership in a "landed" U.S. business activity can trigger a U.S. tax bill and filing.  If a nonresident trader owns a U.S.-brokerage account and spends more than 183 days in the United States (meeting either U.S. substantial presence test), U.S. source net capital gains are subject to U.S. tax.  Most U.S. tax treaties contain provisions that reduce or eliminate tax on capital gains.  The trader could also make a mark-to-market election for the trading activity to be taxed at lower rates.  Being part of a U.S. proprietary trading firm business on a K-1 or W-2 basis triggers exposure to U.S. taxation.

U.S. Taxes The United States taxes citizens, businesses and residents on worldwide income.  It also taxes nonresident individuals (meaning no green card or long-term U.S. presence) and businesses on U.S. source income at tiered rates based on net taxable income. Most other U.S. source income is taxed at a flat 30% rate through payer withholding.  Withholding taxes often are reduced or eliminated in the case of payments to residents of countries with which the U.S. has an income tax treaty.  In addition, certain statutory exemptions from withholding taxes are provided. Income of a non-resident alien individual or foreign corporation that is effectively connected with the conduct of a trade or business in the United States is subject to tax at the normal graduated rates based on net taxable income.

Deductions are allowed in computing effectively connected taxable income (ECI).  Withholding taxes often are reduced or eliminated in the case of payments to residents of countries with which the U.S. has an income tax treaty. In addition, certain statutory exemptions from withholding taxes are provided.  U.S. source non-ECI connected capital gains of non-resident alien individuals and foreign corporations generally are exempt from U.S. tax, with two exceptions: (1) gains realized by a non-resident alien individual who is present in the U.S. for at least 183 days during the taxable year, and (2) certain gains from the disposition of interests in U.S. real estate.  The source of income received by non-resident alien individuals and foreign corporations is determined under rules contained in the Internal Revenue Code (Code).  Interest and dividends paid by a U.S. citizen or resident or by a U.S. corporation generally are considered U.S. source income.

U.S. Individual Investors U.S. taxable investors in an offshore fund structured as a corporation may be exposed to onerous tax rules applicable to controlled foreign corporations, foreign personal holding companies, or a passive foreign investment companies (PFIC).  To attract U.S. individual investors, fund sponsors of an offshore fund or offshore master fund should elect to have it treated as a partnership (for U.S. tax purposes only) so that these U.S. investors avoid harsh tax rules.  Under the U.S. entity classification rules (i.e., check-the-box) an offshore fund elects to be treated as a partnership for U.S. tax purposes by filing Form 8832, "Entity Classification Election."

U.S. State Taxes Although offshore funds generally do not have nexus to the states, many states still require partnerships to file state partnership tax returns if they have partners that are residents of their jurisdiction.  This could result in an offshore fund with U.S. partnership tax status being required to file a state tax return even though it arguably may not be required to file a Form 1065 since the partnership has no U.S. income.  Such state and local partnership returns may require the identity of all partners (including foreign partners) to be included as part of the return.  An offshore fund electing partnership status should carefully analyze the connection of its activities to the United States and the residencies of its U.S. investors to determine federal and state filing requirements as well as provide proper disclosure as to these filing obligations to its foreign investors.

US Persons & Foreign Financial Accounts The Bank Secrecy Act of 1970 (BSA) requires U.S. citizens and residents (including individuals of any age, corporations, partnerships, trusts, and estates) who have financial interests in or signature or other authority over any Financial Accounts in a foreign country are required to e-file FinCEN Form-114 formerly TD F 90-22.1 with the U.S. Department of Treasury if the aggregate value of all such accounts exceed $10,000 at any time during the period covered by their tax returns. FBAR filing requirements also apply to those with direct or indirect control over a foreign entity with foreign financial accounts (even if the taxpayer does not have a foreign financial account of its own). Foreign financial ccounts include bank accounts, brokerage accounts, retirement plan accounts, mutual funds and life insurance with cash value, among other things. FinCEN Form-114 must be filed by June 30 of the year following the year covered by the taxpayer's tax returns.  No extensions are available.  All accounts must be disclosed once you meet the filing requirement. Any failure to file (wilful or otherwise) or an incomplete filing may result in a $10,000 penalty.  Contact Us For Assistance

International Taxes Hedge funds should be aware of possible international filings if either they own an interest in a foreign entity or have an investor who is a non-U.S. taxpayer.  Non-compliance with international tax filings could result in significant penalties.  For example, a penalty for late filing of a return could be as high as 25% of the unpaid tax.  In addition, FATCA requires non-U.S. financial institutions and non-U.S. entities (including offshore investment funds) to provide information to the IRS identifying U.S. persons invested in non-U.S. bank and securities accounts.  The legislation is motivated by incidents of U.S. persons failing to report foreign-source income for U.S. income tax purposes. A 30% withholding tax applies on any "withholdable payment” made to a foreign financial institution (FFI) unless the FFI agrees with the IRS to take a number of specific steps pursuant to an FFI agreement.  The specific steps are designed to ensure that U.S. persons are identified and U.S. tax is imposed on their investment income.

Offshore Hedge Funds Offshore funds are organized as corporations or trusts for marketing, tax, and legal reasons.  If U.S. investors invest in or effectively control an offshore fund, complex U.S. tax rules (and complicated U.S. filing requirements) are operable (e.g., controlled foreign corporations, foreign personal holding companies, and passive foreign investment companies (PFIC) and need attention.  Although an offshore fund generally does not have state tax issues, some states require partnerships to file state partnership tax returns if they have partners that are state residents.  This could result in an offshore fund (e.g., one with a check-the-box election in effect and a New York feeder hedge fund as an investor) being required to file a state tax return even if it has no U.S.-source income and no ECI. Some of the issues are manageable, others are not and the offshore fund may be better off skipping or significantly limiting the presence of U.S. investors. Learn More About Offshore Hedge Funds

U.S. tax-exempt investors prefer offshore funds because of tax considerations. Under U.S. law a tax-exempt investor (such as an IRA, an ERISA-type retirement plan, a foundation, or an endowment) is liable for income tax on "unrelated business taxable income" (UBTI or UBIT) notwithstanding its tax-exempt status.  This tax exposure exists when a U.S. tax-exempt investor invests in a fund that trades on margin.  In those cases where complete investor confidentiality and privacy are necessary, an offshore fund should not accept any U.S. investors (tax-exempt or otherwise) and the fund manager should not be located in the United States.

Master Hedge Funds A master fund allows a fund manager to manage money for a broad spectrum of investors.  The master fund is organized as an offshore corporation or trust (but can be taxed as a partnership only for U.S. tax purposes via a check-the-box election filed on Form 8832). A fund manager can pool money from country-specific feeder funds in the master fund.  Trading gains are allocated to the feeder funds based on the percentage of assets under management.

International Traders Many international traders own U.S.-brokerage accounts and wonder if they will owe U.S. taxes.  When a nonresident trader has a U.S. brokerage account, only interest and dividends earnings are subject to U.S. withholding tax.  No U.S. withholding tax should apply to capital gains.  Many brokerages will withhold taxes anyway. Nonresidents (individual or business) can file for a tax refund using a Form 1040NR and then properly structure their U.S. focused trading to prevent mistakes in the future.  In most cases, U.S. tax liability does not arise.  However, ownership in a "landed" U.S. business activity can trigger a U.S. tax bill and filing. If a nonresident trader owns a U.S.-brokerage account and spends more than 183 days in the United States (meeting either U.S. substantial presence test), U.S. source net capital gains are subject to U.S. tax.  Most U.S. tax treaties contain provisions that reduce or eliminate tax on capital gains.  The trader could also make a mark-to-market election for the trading activity to be taxed at lower rates.  Being part of a U.S. proprietary trading firm business on a K-1 or W-2 basis triggers exposure to U.S. taxation.

U.S. Taxes The United States taxes citizens, businesses and residents on worldwide income. It also taxes nonresident individuals (meaning no green card or long-term U.S. presence) and businesses on U.S. source income at tiered rates based on net taxable income. Most other U.S. source income is taxed at a flat 30% rate through payer withholding. Withholding taxes often are reduced or eliminated in the case of payments to residents of countries with which the U.S. has an income tax treaty. In addition, certain statutory exemptions from withholding taxes are provided. Income of a non-resident alien individual or foreign corporation that is effectively connected with the conduct of a trade or business in the United States is subject to tax at the normal graduated rates based on net taxable income.

Deductions are allowed in computing effectively connected taxable income (ECI). Withholding taxes often are reduced or eliminated in the case of payments to residents of countries with which the U.S. has an income tax treaty.  In addition, certain statutory exemptions from withholding taxes are provided. U.S. source non-ECI connected capital gains of non-resident alien individuals and foreign corporations generally are exempt from U.S. tax, with two exceptions: (1) gains realized by a non-resident alien individual who is present in the U.S. for at least 183 days during the taxable year, and (2) certain gains from the disposition of interests in U.S. real estate.  The source of income received by non-resident alien individuals and foreign corporations is determined under rules contained in the Internal Revenue Code (Code).  Interest and dividends paid by a U.S. citizen or resident or by a U.S. corporation generally are considered U.S. source income. Need Help?  Contact Us for Assistance

Call Us First  We are experts in international hedge funds and tax. Click on any reference below to our leading articles:

Strategic Hedge Fund Planning by Hannah Terhune.  Wilmott Magazine Ltd. (Volume 2013, Issue 63, pages 8-11 January 2013).

Hedge Funds - Limited Partners' Right of Access After Parkcentral Global, L.P., v. Brown Investment Management, L.P. by Jim Brennan.   Cititrust Edge Magazine (4th Quarter 2012).

Strategic Hedge Fund Planningby Hannah Terhune.  Canadian Hedgewatch (March 2012).

Strategic Hedge Fund Planning by Hannah Terhune.  MoneyScience (March 2012)

Hedge Funds - Limited Partners' Right of Access After Parkcentral Global, L.P., v. Brown Investment Management, L.P. by Jim Brennan.  Canadian Hedgewatch (July 2011).

Planning for Cross-Border Financing Arrangements.  Practical International Tax Strategies (May 31, 2011).

U.S.--Tax Traps of Non-U.S. Issuer Debt Offerings.  Practical International Tax Strategies (April 15, 2011).

America the Beautiful Tax Haven.  Cititrust Edge Magazine (1st Quarter 2011).

Offshore Hedge Fund Focus:  Master & Feeder.  Cititrust Edge Magazine (4th Quarter 2010).

U.S.--Cross Border Credit Agreements:  Planning for U.S. Withholding Taxes.  Practical International Tax Strategies (November 15, 2010).

Starting an Offshore Fund.  themanager.org (June 2008).

Mixing Investment Adviser and Brokerage Services.  Hedge Fund Monthly by EurekaHedge.com (October 2007).

Offshore Fund Taxation.  Hedge Fund Monthly by EurekaHedge.com (May 2007).

Forex Trader to Forex Manager.  Offshore Business Magazine (November 2006).

Forex Trader to Forex Fund Manager:  The Path to Success.  Hedge Fund Monthly by EurekaHedge.com (October 2006).

Drafting Hedge Fund Performance Allocations.  Hedge Fund Monthly by EurekaHedge.com (August 2006).

Como Crear su Propio Hedge Fund by Hannah M. Terhune, Eva Porras, Argilio Rodriguez and Garrett Fisher (2006).

Offshore Hedge Funds: Focus on Master/Feeders by Hannah M. Terhune (2006).

Temas Sobre Impuestos de Sociedades Colectivas para Hedge Funds en Paraiso Fiscal by Hannah M. Terhune (2006).

Establish a Marketable Track Record with an Incubator Fund by Hannah M. Terhune (2006).

Must I Register as a Commodity Pool Operator? by Hannah M. Terhune (2006).

Do’s and Don’ts for Crafting Hedge Fund Peformance Allocations by Roger D. Lorence and Hannah M. Terhune. Derivatives:
Financial Products Report (an RIA publication) (September 2005).

Trading Foreign Index Contracts? Know the Tax Rules Before You Trade by Hannah M. Terhune and Roger D. Lorence. Stocks, Futures and Options (June 2005).

Practical Strategies For Section 475(f) Elections by Roger D. Lorence and Hannah M. Terhune. Derivatives Financial Products Report (WG&L/RIA,a Thompson Company) (March 2005).

Forex Hedge Fund Management by Hannah Terhune and Roger D. Lorence.  Currency Trader (March 2005).

Advising Clients on Internet Server Co-Location Agreements, Practical International Tax Strategies (March 15, 2004).

Structuring and Financing International Operations Using Hybrid Entities and Tax-Efficient Financing Practical U.S./International Tax Strategies (Jan. 15, 2004).

Hedge Fund Compensation Arrangements. Practical U.S./Domestic Tax Strategies at Page 18 (Dec. 2003).

U.S. Inbound Investment – The Portfolio Interest Exemption. Practical U.S./International Tax Strategies (Dec. 15, 2003).

Foreign Futures Planning: The 60/40 Question. Practical U.S./International Tax Strategies at Page 12 (Sept. 30, 2003).

Managing Offshore Hedge Funds - A View from the Beach: Practical U.S./International Tax Strategies at Page 9 (June 15, 2003).

Offshore Hedge Funds - Master/Feeder Compliance Issues: Practical U.S./International Tax Strategies at Page 9 (May 15, 2003).

Ready for Help? Please call us (307) 213-4732 or e-mail Hannah Terhune, international hedge fund and tax attorney.

Capital Management Services Group, Inc. is a foremost professional authority in the hedge fund industry.  Ms. Terhune's numerous articles on hedge funds and international tax matters have appeared in publications worldwide. Read Our Leading Media Content and Articles by Hannah Terhune on Hedge Funds and International Tax Planning, Chances are, if you have read (or are reading) anything relating to starting a hedge fund, Ms. Terhune wrote it first. Read Our Client Comments and Read About Hannah Terhune on LinkedIn.  When you consult with us, you have access to a unique and very desirable blend of securities, tax, and business experience. Give us the opportunity to put our knowledge and expertise to work for you. We continuosly provide the highest quality services at competitive rates. Give us a call and let us prove all we can do for you.  You can get answers to your specific questions in a consultation. We are confident that when you are finished with your consultation you will be impressed and more informed about your business plans than before. The views expressed on this website are subject to change based upon new information, new technology, consideration of new perspectives and/or for no reason at all. This website exists for educational purposes and nothing on this website should be considered as legal advice.  Website content and design are copyrighted 2022© by Hannah M. Terhune and all rights are reserved.