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However, if the taxpayer terminates a GST trust election for a trust for which transfers were subject to an ETIP and such termination is filed by the year in which the ETIP expires, the termination will effectively release prior transfers to the trust that were otherwise subject to a prior GST trust election.
The IRS ruled that, because the LLCs and the LP were disregarded as entities separate from their owners, the fact that the LLCs or LP owned the S corporation would not terminate the S election.
One of the dangers inherent in any transaction involving the stock of a qualified Subchapter S subsidiary (QSub) is that it may inadvertently terminate the parent's QSub election.
The Service ruled that the temporary conversions did not terminate the initial S election.
simply ensure that the S corporation's articles of incorporation authorize only one class of stock), there are several traps that could give rise to a prohibited second class of stock and terminate S status.
If the taxpayer terminates the swap at that time, the taxpayer will receive a payment from its counterparty, representing the present value of anticipated future payments under the swap.