.- We can add language to the documents that allows preferential treatment to large institutional equity.

For federal income tax reporting this means the SMLLC is dissolved and there's no distinction between the SMLLC's assets/income and the owner's assets/income.The tax treatment of you holding the property directly vs through a SMLLC taxed as a disregarded entity will be 100% the same. 

Being a member of a protected class doesn’t provide extra privileges it is used to insure equal treatment

I think his taxes would be less with capital gain treatment because he would not have to pay self-employment tax. 

ONLY thing that made it a viable investment for me was the HUGE tax savings I got up front in years were I had massive ordianary income and I saved 100s of thousands that there is no way to get out of or deffer other than this tax treatment.. at least that what I keep telling myself.. 

Any recommendations for window treatments?

With a sewage treatment or septic, my parish (county to non-Louisiana people) requires a permit to turn the power on once it has been turned off or even transferred. 

You can build a Small knee wall to conceal the side of the range and provide a visual termination point for the kitchen.

Sometimes several treatments fail to do it.

If the partnership is throwing off ECI, it may be beneficial for the NRAs to invest in the LLC through another LLC taxed as a C Corp.US tax treaties with the UK and Ireland would need to be examined.Creating disregarded SMLLCs for the NRAs might create issues with lost tax credits due to the disparity in treatment between countries.