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TOPICS / PASSTHROUGHS

S Corporation Income Taxation

S Corporations and Disregarded Entities—Qualification as Shareholders

Executive Summary S corporations may be owned through a network of trusts, partnerships and LLCs when DEs are properly used. Letter Ruling 200439028 presents a variation on recent ownership schemes, with a layered structure involving DEs. The intertwining structure of complex ownership networks often leaves the S corporation’s eligibility status

S Holding Companies and F Reorgs.

In yet another in a series of F reorganization rulings, the IRS issued Letter Ruling 200701017, holding that the formation of a new corporation, followed by the contribution of S stock and an immediate qualified subchapter S subsidiary (QSub) election, will be treated as an F reorganization (i.e., a mere

Adjusting Basis of Inherited S Stock for IRD

Editor: Albert B. Ellentuck, Esq. Income in respect of a decedent (IRD) generally consists of items of gross income a decedent was entitled to at death that, because of the decedent’s method of accounting, were not included in the final individual return; see Regs. Sec. 1.691(a)-1(b). IRD is included in

TAX PRACTICE MANAGEMENT

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2025 tax software survey

AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.

Tax Clinic

Deductibility of transaction costs incurred by an indirectly acquired entity

IRS issues guidance on treaty application to reverse foreign hybrids

IRS removes associated-property rule from interest capitalization regulations

Practical tax issues related to qualified reopenings

Partner redemptions from ‘dry’ partnerships