B) substantially all of the stock of which (by value) is held directly (or indirectly through 1 or more partnerships, S corporations, or qualified personal service corporations
A personal service activity is one in any of eight fields also specified as those of personal service corporations
subject to a 35% flat corporate income tax rate in section 448(d)(2): health, law, engineering, architecture, accounting, actuarial science, performing arts, or consulting, with the addition of "any other trade or business in which capital is not a material income-producing factor.
9) Despite this artful drafting, personal service corporations
may be vulnerable to IRS attack under [section] 482 (e.
But personal service corporations
, such as accountants, doctors and lawyers, are required to have a calendar year.
However, when an accounting practice or other personal service business is incorporated, numerous tax provisions relating specifically to Personal Service Corporations
Personal service corporations
, S-corporations and C-corporations with gross receipts of less than $5 million also can use the cash method of accounting.
As was discussed in the October 1989 SURVEY OF CURRENT BUSINESS, lump-sum payments by personal service corporations
to their owner-employees (doctors, lawyers, etc.
Section 11(b)(2) imposes a flat 35% tax rate on personal service corporations
rather than allowing them to use the progressive rate structure provided for most other corporations.
469 apply to individuals, trusts, estates, personal service corporations
, and closely held C corporations.
starting with 1987; and Personal Service Corporations
The rules apply to individuals, trusts, estates and personal service corporations
Hence, limitations would not apply to employees of a partnership who perform services substantially identical to those performed by corporate executives at a competing firm, nor would they apply to non-executive employees or to employee-owners of personal service corporations