Chapter 40: Limited Liability Companies, Limited Partnerships, and Limited Liability Limited Partnerships
- Limited Liability Companies
- Uniform Limited Liability Company Act of 1996 (ULLCA)
- Default rules that govern an LLC when there is no contrary agreement by its owners
- Treats LLCs and their owners like RUPA treats LLPs and their partners
- Tax Treatment
- May elect to be taxed like a partnership or corporation
- Most elect to be taxed like a partnership
- LLC pays no federal tax
- Owners report income and losses on their individual returns
- Passive investors may use their shares of losses to offset only income from other passive investments
- Formation
- Must file articles of organization with the secretary of state
- Must include
- Name of LLC, including words “limited liability company,” “limited company,” “LLC” or “L.L.C.”
- Duration
- Name and address of registered agent
- Must state whether
- Member-managed; or
- Mangager-managed, including names of initial managers
- Must indicate if LLC has a term; if not, it is deemed at will
- Owners
- Called members
- May include an individual, partnership, corporation, or another LLC
- Once formed
- May sue and be sued
- Can buy, hold and sell property
- Can make contracts and incur liabilities
- Foreign LLCs
- Created in one state (domestic state) but conducts business in another (foreign state)
- Foreign states may require that the LLC obtain a certificate of authority
- Foreign certificate of authority must
- Be filed with the secretary of state
- Include
- Name and address
- Agent for service of process
- Payment of a fee
- If a LLC fails to obtain a certificate of authority in foreign state,
- Contracts are still valid
- Members retain limited liability
- May be required to pay back fees and fines
- Disabled from using the foreign state’s courts until properly files certificate of authority
- Appoints foreign state’s secretary of state as agent for service
- Members’ Rights and Liabilities
- Limited Liability
- No individual liability on LLC contracts unless signed in personal capacity
- Liability usually limited to members’ capital contributions
- Must make capital contributions to the LLC as agreed
- Management Rights
- Member-managed
- Share equal rights in management
- Each member is an agent with implied authority
- Members also have apparent authority
- Manager-managed
- Managers elected and removed by majority vote
- Each manager shares equal rights in management as an agent
- Managers have implied authority and apparent authority
- Most matters may be conducted by individual managing members or managers or by a majority of managing members or managers
- Matters requiring consent of all members include
a)Amending of the operating agreement
b)Admission of new members
c)Redemption of a member’s interest
d)Sale of substantially all of the LLC’s assets
- LLC is not ordinarily liable for wrongful acts of non-managing members
- Non-managing members owe no fiduciary duties
- Duties: each member in a member-managed LLC and each manager in a manager-managed LLC are fiduciaries
- Managing member or manager
- Must account for LLC property and funds
- Not compete with LLC
- Exercise duty of care
- All members owe a duty of good faith and fair dealing
- Distributions: share profits and other distributions equally
- Ownership Interests
- Personal property of the member
- Limited ability to sell or transfer
- May transfer right to receive distributions, but
- Transferee does not become LLC member
a)No right to manage
b)Only a limited right to information
c)May obtain judicial dissolution if LLC is at will or term has expired
- Creditors do not own the distribution interest until foreclosure and purchase
- Members’ Dissociation and LLC Dissolution
- Member Dissociations
- Power to dissociate by withdrawing from LLC at any time
- Dissociation is caused by
- Death
- Having a guardian appointed
- Being adjudged legally incompetent
- Being a debtor in bankruptcy
- Transferring all distributional interest
- Being expelled by other members
- Wrongful dissociations breach the operating agreement
- Withdrawing before LLC term has expired
- Being a debtor in bankruptcy
- Being expelled by court
- Wrongfully dissociating member is liable for damages
- Right to manage terminates
- May still have apparent authority unless notice given to third parties
- Personal notice to creditors
- Filing a Statement of dissociation with the secretary of state
- No right to force the LLC to dissolve and liquidate assets
- Remaining members must pay value of distributional interest
- Must purchase interest at fair value within 120 days of member’s dissociation if at will
- If term LLC, must pay the value of interest within 120 days after the end of term
- Dissolution
- Ordinarily must be wound up after dissolution
- Few events automatically cause dissolution
- Event making it unlawful for the LLC business to continue
- Judicial dissolution at the request of a member or transferee because
a)LLC cannot practicably carry on its business
b)Is being managed illegally or oppressively; or
c)Failed to purchase a dissociated member’s interest on date required
- Administrative dissolution by secretary of state
- Any member who has not wrongfully dissociated may wind up
- LLC is bound by the reasonable acts of members during winding up
- May be liable for actions that continue the business and are inconsistent with winding up unless notice is given to third parties in a reasonable manner
a)Email, letter or phone call
b)Filing a Notice of Dissociation, effective 90 days later
- Proceeds are distributed
- First to creditors, including members who are creditors
- Then members’ contributions are returned
- Any remaining proceeds are distributed in equal shares
- Ordinarily creditors have no recourse if LLC’s assets are insufficient, unless members have not paid all of the capital promised to LLC
- Effect of Operating Agreement
- ULLCA gives members much flexibility to arrange affairs in the way they want
- In Re Garrison-Ashburn, LC
- Member dissociated from LLC by filing a petition in bankruptcy
- Dissociated member was divested of all rights to participate in management or operation of the company
- Limited Partnerships and Limited Liability Limited Partnerships
- Uniform Limited Partnership Act of 2001 (ULPA)
- Will soon be the dominant limited partnership law in the U.S.
- 11 states have adopted it
- Applies to both LPs and LLLPs
- Use of LPs and LLLPs
- Primarily used for tax shelter ventures
- General partners receive a greater tax shelter advantage
- Losses can offset income from any other sources, while
- Limited partners can only use losses to offset income from other passive investments
- LPs are also used by family businesses because of limited right to dissociate
- Creation
- Certificate of limited partnership must be executed and submitted to secretary of state
- Must be signed by all general partners
- Must include
- Its address
- Registered agent for service of process
- General partners’ names and addresses
- Whether it is an LP or LLLP
- ULPA provides for the continuing life of a LP or LLLP
- Any person may be a general partner
- Natural person
- Partnership
- LLC
- Trust
- Estate
- Association
- Corporation
- Defective Compliance with LP Statute
- ULPA requires substantial compliance or LP does not exist
- No substantial compliance usually if
- Failure to file a certificate of limited partnership
- Filing of a defective certificate
- Misstate name of LP
- Erroneously identify business form
- Limited partners
- If designated as a general partner, but individual believes he or she is a limited partner, may be liable unless
- Good faith belief; and
- Upon discovering he or she is not a limited partner,
a)Causes a proper certificate of limited partnership to be filed; or
b)Withdraws from future equity participation in the firm by a filing a certificate declaring such withdrawal
- Remains liable to third parties who believe in good faith that he or she is a general partner
- ULPA has no provision to protect general partners who erroneously believe an LLLP has been formed
- Foreign Limited Partnerships
- Domestic in state where organized
- Foreign in all other states
- Laws of domestic state apply to internal affairs
- Must file an application for a certificate of authority with the secretary of state of the foreign state to transact business there, and include
- Name and address of LP
- Names and addresses of general partners
- Name and address of agent for service of process
- An unregistered foreign LP
- May not use foreign state’s courts to sue
- Contracts still valid
- Rights and Liabilities of LPs and LLLPs
- Capital Contributions
- Partners obligated to contribute as promised
- Obligation may be enforced by LP or any of its creditors
- Profits and losses shared based on value of each partner’s capital contribution unless written agreement
- Voting Rights
- Actions that must be approved by all partners
- Amendment of limited partnership agreement
- Amendment of limited partnership certificate
- Sale or transfer of substantially all of the LP’s assets outside the ordinary course of business
- Limited partners have no right to vote on any matter as a class
- No new partner may be admitted unless each partner has consented
- Derivative Actions
- Usually the general partners hold the power to sue on behalf of the LP
- Exceptions
- If a limited partner asks the general partners to sue someone who has harmed the LP and they refuse, the limited partner may bring a derivative suit
- Also may bring suit if shows that asking the general partners will be a futile effort
- Recovery goes to the LP
- Partner’s Transferable Interest
- Personal property of each partner in a LP
- Buyer or transferee (or creditor with a charging order) is entitled only to receive the partner’s share of distributions
- Power and Right to Withdraw
- Power to withdraw from LP at any time
- ULPA gives no right to withdraw, absent a contrary provision in LP agreement
- Other Rights of General Partners
- Same right to manage and same agency powers as in ordinary partnership
- No right to compensation beyond share of the profits
- Other Liabilities of General Partners
- Liability
- In LP: unlimited liability to creditors
- In LLLP: liability is limited to capital contributions
a)Exception: may not escape liability for torts the general partner, himself, commits in the course of business
b)Protected from other torts, such as torts of other general partners
- Fiduciary Duties
- Must account for LP property
- Not compete against the partnership
- Not self-deal with partnership
- Duty of care
- Other Rights of Limited Partners
- Right to be informed about partnership affairs
- General partners must provide financial information and tax returns to limited partners on demand
- May inspect and copy a list of the partners, information concerning contributions by partners, the certificate of LP, tax returns, and partnership agreements
- Other Liabilities of Limited Partners
- Liability
- No further liability once contributed all of promised capital
- ULPA eliminates liability of limited partners who participate in control of the business
- Duties
- No limited partner owes fiduciary duties (unless an agent)
- Owe a duty to act in good faith and fair dealing
- Partners’ Dissociations and LP Dissolution
- Partners’ Dissociations
- Limited Partners
- Occurs upon
a)Death
b)Withdrawal
c)Expulsion from partnership
1)By partners: must be unanimous
- Transferred all of transferable interest
- Suffered a charging order
- Illegal to conduct business with limited partner
2)By court
- Engaged in wrongful conduct negatively affecting business
- Willfully and persistently breached partnership agreement or duty of good faith and fair dealing
- Retain right to receive distributions and liquidation value
- General Partners
- Occurs upon
a)Death
b)Withdrawal
c)Expulsion
d)Mental or physical inability to care for self
e)Unable to perform as a general partner (determined by court)
f)Debtor in bankruptcy
g)Assigns assets to creditors
h)Custodian appointed over property
i)By a vote of all other partners or by court, the same as a limited partner
- Ends right to manage
- Released from fiduciary duties (except duty of confidentiality)
- May retain apparent authority unless notice given
a)Email or phone calls
b)Filing of Notice of Dissociation
- Liable on obligations incurred during partnership unless creditors release
- Not liable on obligations incurred after dissociation if
a)Proper notice to third parties
b)More that two years has elapsed since dissociation
c)In LLLP, no need for dissociated general partners to be released from liability
- Effect of LP Agreement
- Can eliminate a limited partner’s right to withdraw
- Cannot eliminate a general partner’s right to withdraw
- LP Dissolutions
- Does not dissolve and wind up merely because a partner dissociates
- Dissolved and wound up only if
- All general partners and limited partners owning a majority of the claims to the distributions vote for dissolution
- If a general partner dissociates and partners owning a majority of the claims to partners’ distributions so vote
- If last general partner or limited partner dissociates and is not replaced within 90 days
- A court dissolves the LP because it is not reasonably practical to carry on the business
- Administrative dissolution by the secretary of state is possible if
- LP fails to pay fees and taxes due
- Fails to deliver annual report
- Winding up follows automatically after dissolution
- General partners have the power to wind up
- Unless dissociated
- If no remaining general partner to wind up, limited partners may appoint one
- Assets distributed
- First to creditors
- Remainder paid to partners in proportions as shared distributions
- If insufficient assets to pay creditors
- Persons who were general partners when obligation occurred must contribute cash in the same proportions that they shared distributions when obligation incurred