S Corporation Income Taxation
The IRS waived the penalty for corporations that did not make estimated payments of corporate AMT for their 2023 tax year, saying the move is “in the interest of sound tax administration.”
Shareholder basis and other applicable loss limitations must be applied in a specified order, with differing rules.
taxpayers and practitioners face uncertainty regarding the timing of the deduction provided for in Notice 2020-75.
The guidance focuses on nonidentical governing provisions; principal-purpose determinations regarding the one-class-of-stock requirement; disproportionate distributions; certain errors on forms; missing administrative or acceptance letters for an S or QSub election; and the requirement to file returns consistent with an S election.
While it might stand to reason that if there is only one shareholder, then there can be only one class of stock, that is not necessarily what the Code and regulations provide.
Revised draft instructions for partnership and S corporation Schedules K-2 and K-3 contain significant changes to the requirements to qualify for the domestic filing exception for filing and furnishing the 2022 schedules.
The IRS addressed a consolidated corporation’s request to apply Sec. 1362(f) to provide relief from termination of the corporation’s subsidiary’s S corporation and QSub elections.
This item discusses nonprorated S corporation rollovers and the unexpected tax consequences.
Twenty-nine states have enacted a passthrough entity tax as a possible workaround to the federal state and local tax deduction cap.
Practitioners may face a difficult analysis in helping their clients understand their possible PTE election opportunities.
A number of disqualifying events can terminate a corporation’s S status, and not all of those events are listed in the statute or immediately obvious.
The AICPA S Corporation Taxation Technical Resource Panel summarizes recent developments.
Approval of an S election by the IRS and/or a state jurisdiction does not mean that S corporation status remains safe and sound forever.
Generally, a trust cannot hold stock of an S corporation; however, grantor trusts, testamentary trusts, voting trusts, ESBTs, and QSSTs are permissible S corporation shareholders (Sec. 1361(c)(2)).
This article compares the relative advantages and disadvantages of a QSST versus an ESBT in estate planning.
The IRS delays e-filing capability for schedules reporting S shareholders’ items of international tax relevance, earlier forecast for mid-June, to July 24.
In eight new FAQs on its website, the IRS covers some special issues, including several that it says will be added to the forms’ instructions.
AAA and AE&P calculations are key to determining stock basis and, thus, the taxability of shareholder distributions.
S corporation stock was not subject to a substantial risk of forfeiture because the stock forfeiture provision was unlikely to be enforced.
The IRS, citing earlier problems e-filing a new form reporting S corporation owners’ basis, has granted relief to certain farmers and fishermen who missed their March 1 filing deadline.
