The tax preparer incorrectly concluded that the personal holding company tax
did not apply.
Important factors that could cause actual results to differ materially from those discussed in such forward-looking statements include: the outcome of settlement discussions with the Internal Revenue Service regarding the final amount of the potential tax liabilities and associated payments related to the previously disclosed personal holding company tax
matters; uncertainty regarding the effect or outcome of the company's announced sale to an affiliate of Blackstone Capital Partners V L.
the flat tax, the accumulated earnings tax and the personal holding company tax
And several C-corporation downsides, such as excess compensation, personal holding company tax
and unreasonable accumulation of earnings are generally not problems for S-corporations.
Chapter 7 covers the determination of consolidated tax liability, delving into areas such as the alternative minimum tax, the personal holding company tax
, and the accumulated earnings tax.
becoming subject to personal holding company tax
for federal income tax purposes for 2005.
It should also be noted that if a dividend is paid from a TR, S to avoid personal holding company tax
, when received by the REIT the dividend will not represent qualifying income for purposes of the 75% gross income test set forth under Sec.
Other corporate problems may also emerge, such as the accumulated excess earnings or personal holding company tax
The Act specifically provides that a pension trust will not be treated as a single individual for purposes of the `five-or- fewer-rule' and stipulates that a REIT is not subject to the personal holding company tax
on its undistributed income.
TLC Beatrice said that the sale of its French food distribution business left it with a substantial cash position and that the payment of a special dividend will enable the company to eliminate its potential personal holding company tax
liability while allowing its shareholders to participate in the company's increased profits.
A similar issue could arise with the personal holding company tax
1 Report of Foreign Bank Account and Schedule PH Personal Holding Company Tax