336(e) election is available to both domestic C corporation and S corporation shareholders for qualifying transactions occurring on or after May 15, 2013.
In dispositions where T is an S corporation, all of its shareholders must also make the election, whether or not they are selling their stock, for the election to be effective.
A corporation electing under IRC section 1362 to be taxed as an S corporation
is subject to various ownership restrictions, including the requirement that shareholders must be individuals (section 1361(b)(1)(B)).
1377(a)(2) applies to situations in which a shareholder terminates his or her complete interest in the S corporation
S is an S corporation
in the business of tax return preparation.
1502-32 is adapted from the method of calculating basis adjustments for partnership interests and shares in a Subchapter S corporation
In the first, X was an S corporation
that owned 100% of the stock of Sub1, which X elected to treat as a qualified subchapter S subsidiary (QSub) under Sec.
Further, it provided that an S corporation
that wholly owns another domestic corporation can elect to treat such subsidiary as a QSub, allowing flowthrough treatment of the QSub's tax items.
TC Memo 1996-303, the court considered the accountant's testimony and advice regarding the reasonableness of the taxpayer's (an S corporation
president's) compensation, even though the CPA was not a compensation expert; see also Est.
1367(a)(2), an S shareholder's basis in an S corporation
is decreased by each of the following items:
It is not uncommon for an S shareholder with zero stock basis to loan money to the S corporation
to use either current year or suspended losses.
The rules are similar to those for determining basis in partnership interests and basis in stock in S corporations