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VIDEO |
E-BOOK |
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| I. OVERVIEW |
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I. OVERVIEW |
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Advantages |
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C Corps over S Corps |
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Congressional Purpose |
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S Corps over C Corps
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Taxation of the S Corporation
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S Corps over Partnerships
/ LLCs
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Shareholder Taxation
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Partnerships / LLCs over S Corps
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Coordination with Subchapter
C
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Audit Risks for S Corporations
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| II. ELIGIBILITY |
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II. ELIGIBILITY |
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Small Business Corporation
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A. Small Business Corporation
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Affiliated Corporations
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Domestic Corporation
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Number of Shareholders
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Ineligible Corporation
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One Class of Stock Limitation
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Authorized Number of
Shareholders
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Straight
Debt
Safe
Harbor
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One Class of Stock Limitation
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Eligible Shareholders
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Eligible Shareholders
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Partnership of S Corporations
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| III. ELECTION |
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III. ELECTION |
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Statutory Requirements |
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General
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Late Election
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Time of Election
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Effective Date of Election
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Five-Year Restriction
After Prior Termination
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IV. TERMINATION
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IV. TERMINATION |
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Revocation
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General
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Passive Investment Income
Restriction
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Effective Date of Termination
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Passive Gross Receipts
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Allocations of Income
on Termination
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Passive Rent
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Special Timing Rules
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Managing the Problem
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Revocation
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Inadvertent Termination
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Passive Investment Income
Restriction
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Active or Inactive Business
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Inadvertent Termination
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V. TAXES IMPOSED ON THE
S CORP
ORATION
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V. TAXES IMPOSED ON THE
S CORPORATION
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Built-In Gains Tax
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General Tax Treatment
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Example of Built-In
Gain Rules
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Taxation of S Corporation
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Taxable Income Limitation |
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Practice and Planning |
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Excess Passive Investment
Income
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| VI. PASS-THROUGH INCOME |
VI. PASS-THROUGH INCOME |
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Conduit Tax System
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Conduit Tax System
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Net Operating Loss Deduction
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Shareholder Treatment
of Items
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Allocation of Income
on Change of Ownership
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Basis Adjustment for
Shareholders
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Loss Limitation
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Shareholders Loans
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Passive Activity Losses
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Losses After Termination
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At Risk Limits
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Transfer of Stock to
Family Members
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Compensation and FICA
Taxes
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Reasonable Salary
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Restricted Section 83
Stock
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No Double Taxation
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| VII. DISTRIBUTIONS |
VII. DISTRIBUTIONS |
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No Earnings and Profits
( E&P)
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Treatment of Corporation
Distributions
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With Earnings and Profits
(E&P)
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Accumulated Adjustments
Account
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Review: With and Without
E & P
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Post-Termination Transition
Period
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| VIII. LOAN REPAYMENTS |
VIII. LOAN REPAYMENTS |
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Shareholder Paid More
Than Basis-Gain
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Shareholder Paid Less
Than Basis-Loss
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| IX. TAXABLE YEAR |
IX. TAXABLE YEAR |
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Natural Business Year
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General Rules
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Election of Taxable
Year 444 Election
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Deferral Prohibited
Without a Business Purpose
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Automatic Business Purpose
Test
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Taxable Year Selection
Procedures
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Business Purpose Test
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Election of Taxable
Year Other Than Required Taxable Year
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Required Payments Under
Section 7519
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X. SELECTED TOPICS
IN DEPTH |
X. SELECTED TOPICS
IN DEPTH |
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Subchapter C and Subchapter
S Interface
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Treatment of Fringe
Benefits
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Treatment of Fringe
Benefits
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Treatment of Expenses
Owed to Shareholders
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Interest Deductions
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Interest Deductions
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Interest Deductions
for Loans Intended as
Distributions
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Cancelled Debt Income
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Borrowing to Buy S Corporation
Stock
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Expensed Property – Section
179
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Self-Charged Expenses
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Transfers of Stock to
Third Parties
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Cancelled Debt Income
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Bequest of S Corporation
Stock
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Section 179 – First
Year Expense
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S Corporation Shareholder’s
Unused Losses Upon Disposition
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Stock
Sale
- Gain / Loss Character
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Redemptions
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Allocated Income between
Buyer and Seller
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S Corporations Liquidations
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Bequest of S Corporation
Stock
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S Corporation Conversion
to C With an Initial Public Offering
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Shareholder’s
Unused Losses upon Stock Disposition
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Shareholder Consistency
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Redemption
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Tax Return of S Corporation
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Redemptions and S Corporations
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Statute of Limitations
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Stock Purchase Treated
as Asset Acquisition
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