The IRS issued proposed regulations on the subject of when an S corporation shareholder can increase his or her basis in the S corporation’s stock based on loans to the corporation.
Consideration of tax shelter case about whether warrants issued by an S corporation are a prohibited second class of stock reveals that the entire tax shelter is an arrangement that is a second class of stock.
A qualified subchapter S subsidiary (QSub) is a subsidiary corporation 100% owned by an S corporation that has made a valid QSub election for the subsidiary.
The Tax Court held that shareholders in two related S corporations could increase their basis in one of the corporations by contributing assets to it that they had received in a distribution from the other corporation.
There is room for disagreement, if not confusion, over how to report transactions involving life insurance on the tax returns of S corporations.
The current uncertain economic environment may present an opportunity to exit C status and its attendant double taxation at an acceptable current tax cost.
The IRS issued proposed regulations on when an S corporation shareholder can increase basis in the S corporation’s stock based on loans to the corporation.
Passthrough entities may be overlooking the research tax credit because they are not aware that they are engaged in eligible activities, do not think their activities are qualified, or do not believe they can meet the various requirements.
Properly apportioning real estate expenses between personal and rental use presents several challenges.
Selling shareholders of an S corporation commonly seek a partially tax-deferred rollover of equity. This item describes the differing results between a transaction accomplished through a Sec. 351 transfer and one structured as part sale/part contribution.
The IRS has authority to waive the effect of an invalid election of S corporation status. This article discusses different methods of relief.
The Ninth Circuit, affirming the Tax Court, held that a corporation whose sole shareholder was a Roth IRA was not a valid S corporation.
This article examines five issues corporations commonly encounter in complying with the built-in gains tax.
The Eighth Circuit affirmed a lower court's decision that an S corporation shareholder’s $24,000 salary was not reasonable compensation.
A tax practitioner working with the estate of an S corporation shareholder who died in 2010 must contend with numerous issues. This article points out some of the issues and discusses some of the choices that can be considered.
In an S corporation, employee fringe benefits paid on behalf of a 2% shareholder are subject to special rules.
This article provides an annual update of recent IRS rulings, guidance, and other developments concerning S corporations. It discusses S corporation eligibility, elections, termination issues, second class of stock, and trusts owning S corporation stock.
Temporary and proposed regulations extend the religious and family member FICA and FUTA tax exceptions to disregarded entities.
The IRS issued final regulations clarifying the treatment of disregarded entities with respect to employment and certain excise taxes.
Under Letter Ruling 201122003, if a current ESBT allows for separate and independent trust shares under the trust document, a trust may be treated as both an ESBT and a QSST. This ruling opens the door for additional planning for gifts of S corporation stock to younger generations.