Tax planning opportunities using QSSSs as pass-through entities

Article Abstract:

Liberalized provisions in the Small Business Job Protection Act of 1996 and resultant IRS regulations under IRC section 1361 have provided new business and tax planning opportunities for Subchapter S corporations. S corporations may own qualified subsidiary corporations and may elect to disregard those subsidiaries and treat them as pass-through entities for tax purposes. More Subchapter C corporations and businesses in other forms may elect S corporation status to take advantage of these tax benefits.

Methods, Tax planning, S corporations

---

Subsidiary ownership after "check-the-box": choosing among corporate, single-member LLC and partnership forms

Article Abstract:

Tax consequences are substantially different in accordance with the various forms of business entities which parent corporations may choose for new or reorganized subsidiaries. IRS check-the-box regulations have allowed great flexibility in designing business structures. The advisability of use of partnerships, limited liability companies, or other pass-through entities depends upon nontax reasons and tax reasons which vary situationally for different taxpayers.

Usage, Limited liability companies, Partnership, Partnerships

---

A primer on transfer pricing

Article Abstract:

The author presents an explanation of the concept of and procedures regarding transfer pricing. IRC section 482 mandates arms-length pricing determinations for transactions carried on between related business enterprises. This mandate is controlled by a great quantity of IRS regulatory substantive and procedural rules as well as by case law.

Analysis, Laws, regulations and rules, Tax administration and procedure, Tax administration, Transfer pricing

Similar abstracts:

• Abstracts: Investment opportunities and the structure of executive compensation. Estimates of economic rates of return for the U.S. pharmaceutical industry, 1976-1987
• Abstracts: The warrant supply dries up. All about equities. Warrant buyers: do you feel lucky?
• Abstracts: Transforming portfolio management. Harnessing the team. Credit quality nirvana?
• Abstracts: Top notch options. Schools of thought: first principles. Taking centre stage
• Abstracts: De novo banks and lending to small businesses: an empirical analysis. Measuring the value of strategic alliances in the wake of a financial implosion: evidence from Japan's financial services sector

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.