REAL ESTATE OPERATIONS IN THE CORPORATE FORM -- WHEN DOES IT MAKE SENSE?

Size: px
Start display at page:

Download "REAL ESTATE OPERATIONS IN THE CORPORATE FORM -- WHEN DOES IT MAKE SENSE?"

Transcription

1 REAL ESTATE OPERATIONS IN THE CORPORATE FORM -- WHEN DOES IT MAKE SENSE? I. INTRODUCTION A. Historically real estate owned by partnership or limited partnership. B. Many circumstances favor the use of a corporation taxed under Subchapter C of the I.R.C. of 1986 or Subchapter S of the I.R.C. of C. Advantages of C corporation -- Limitations of C corporation -- circumstances in which S corporation s overcome C corporation disadvantages -- and partnership freezes. II. C CORPORATION ADVANTAGES A. Limited liability - historically the reason C corporations used in various settings: (i) limited liability not assured for active owner except through the corporate form. (ii) money investors in a corporation need not restrict their participation in management to preserve limited liability. B. Centralized management. C. Continuity of existence. D. Free transferability of shares. E. Anonymity of shareholders. IICLE/DOC/KHB/BE

2 (1) limited partnerships under RULPA in Illinois are now able to obtain anonymity but general partners are still disclosed - even if not active. F. Assured tax status. (1) more certainty than partnership tests pursuant to the regulations under I.R.C G. Tax free reorganizations in the future (1) not available to partnerships. H. Income splitting between shareholder and corporation. (i) shareholder and corporation still considered independent and separate taxpayers. both shareholder and corporation benefit from graduated rates, provided incomes not high enough to phase out. Example: See three year tax tables, attached as Exhibit 1. Suppose individual already paying 28% flat tax on other income owns business that produces $50,000 of taxable income. If he operates a sole proprietorship for tax year 1988 he pays 28% tax on $50,000 or $14,000. If operates as C corporation initially pays only 15% on $50,000 or $7,500. Tax Savings of $6,500 (Note: second tax on distribution). Caveat: Disadvantages of C corporation - the inversion of tax rates at higher income levels: 34% v. 28%. (iii) Undistributed C corporation taxable income is not taxed to shareholders. Funds can be used for direct corporation investment, reduction of mortgage indebtedness, fringe benefits - avoiding 2% shareholder floor on some itemized deductions. I. Income Splitting between family members. (i) less available than in the past because unearned income of children under 14 taxed at parent s highest rate. (ii) lesser spread between highest and lowest rates. 2

3 (iii) effective for older kids working summers and vacations - lower tax cost for college or other expenses. J. Medical reimbursement plans more flexible for corporation. (1) deductible for C corporation, not income to shareholder. K. Profit Sharing Plans. L. Timing of deductions and income. (1) generally C corporation can still choose a fiscal year. (ii) limitations on fiscal year for a personal service corporation. M. Separate taxpayer for dealer taint on the sale of property. (i) particularly appropriate for complex and diverse real estate operations - i.e., ownership of an apartment complex and condominium sales in a second complex. (ii) this will be discussed more fully at IV.B. (viii). N. Passive Loss rules, I.R.C (i) general rule: passive losses cannot be offset against portfolio income or active income. (ii) Bozo Game - 3 baskets of income/losses and deduction equivalent credits. (b) (c) active income/losses - income from a trade or business and not portfolio income or passive activity income. portfolio income/losses - income from interest, dividends and royalties, e.g., from investment portfolio. passive income/losses - any activity which involves the conduct of any trade or business in which the taxpayer does not "materially participate." 3

4 (1) material participation is a subjective test. (2) activity must be "regular," "continuous," and "substantial" - terms not defined in I.R.C. Also consider if: (b) (c) activity is taxpayer s principal business? amount of taxpayer s physical presence in the business? extent of taxpayer s personal services? (iii) Impact of passive loss rules depends on type of entity. Types of regular C corporation entities: closely held C corporation - corporation with 5 or fewer shareholders owning directly or indirectly 50% or more in value of the outstanding stock. 469(j)(1), 465 (1) (B), 542 (2). (b) personal service corporation. 469 uses a modified definition of personal service corporation. Generally corporations providing services - professional corporations, financial service firms, etc. (c) corporation that is not a closely held C corporation or personal service corporation. regular corj Dorat ion. (d) Advantages of corporate ownership. See handout 3, "Passive Activity v. Nonpassive Activity." Regular C corporation may offset passive losses against active income and portfolio income. Not subject to disallowance rules of 469. (b) Closely held C corporation may offset passive losses against active income. Cannot offset passive losses against portfolio income. (c) Personal service corporation may not offset passive losses against active income or portfolio income. 4

5 III. (d) Note special rule for defining "active" income for closely held C corporation. Generally shareholders owning 50% or more of the stock must materially participate in the activity. (e) Two caveats before transferring passive activity to C corporation: (1) if activity turns profitable, income will be taxed at higher C corporation rates. (2) deductions and credits that produce the tax loss for passive activity, e.g. accelerated depreciation, are likely to be tax preference items that result in the new corporate alternative minimum tax. (f) Special Rental Activity Rule for Real Estate. See footnote 3 on handout Summarize C corporation advantages. C corporation disadvantages. (1) taxpayer participates in real estate activity. (2) taxpayer s adjusted gross income is less than $100,000. (3) real estate activity loss is $25,000 or less, loss is treated as nonpassive activity - even for individuals, personal service corporations and shareholders of S corporation. A. Because corporations are separate and distinct entities there are various unfavorable tax consequences in a C corporation. B. Double Taxation (1) tax at corporate level and at shareholder level. (ii) Note: Approximately $1.00 in corporate earnings necessary to put $.48 in shareholder pocket. Corporate level tax at 34% and shareholder level tax at 28%. 5

6 Caveat: Tax at corporate level can be reduced by salary payments to shareholder/employee except if they are unreasonable and deemed a dividend. C. CORPORATE TAX RATE HIGHER THAN INDIVIDUAL TAX RATE. Tax Reform Act of 1986 inverted corporate and individual tax rates for first time making corporate "effective tax rates" higher than shareholder "effective tax rates." (1) See handout 2 - tax rate phase-in: corporation compared to married filing jointly. highest marginal rate (1) corporation 34% with 5% surtax (2) married filing jointly 28% with 5% surtax. (b) Difference of marginal rate v. effective rate. (ii) Surtax is a clawback of lower marginal rates on first dollars earned. At corporate income of $335,000 corporation s effective rate or flat rate of 34% is established. For married filing jointly effective rate or flat rate is 28% at 171,900. D. Repeal of the General Utilities Doctrine (i) generally this doctrine allowed a corporation to distribute appreciated property to its shareholders without recognizing a gain on the distribution. Thus circumventing the general regime of double taxation. Tax Reform Act of 1986 eliminated general utilities with certain transitional exceptions. These should be reviewed. (iii) Partnership or S corporation freeze - discussed at Hybrid Use of C corporations, at V. E. CORPORATE ALTERNATIVE MINIMUM TAX (i) TRA of 1986 replaced the 15% corporate add-on minimum tax with a 20% alternative minimum tax.

7 (ii) Corporations tax base for the ANT is expanded: Regular taxable income increased by its tax preferences for the year and adjusted by recomputing designated deductions and items of income. Adjustments generally counteract accelerated deductions or methods of reporting income that defer recognition of taxable income, e.g. accelerated depreciation and completed contract methods of accounting. (iv) Preferences include items like amortization of pollution control facilities, percentage depletion, excess intangible drilling costs, etc. (v) Corporation pays higher of corporate income tax and Alternative Minimum Tax. (vi) Corporation is given a $40,000 exemption against ANTI but that phases out at the rate of 25 cents per dollar for ANTI in excess of $150,000. Phase out of exemption is completed at ANTI of $310,000. (vii) Corporation must keep two sets of books to maintain ANTI for tax purposes - administrative difficulties. (viii) ANT may counteract benefit of Passive loss rules for corporation. F. No pass through of Losses (i) C corporation is separate entity - no loss pass throughs G. Limitations on Related Party Loss Rules (1) losses on transactions between corporation and shareholder are not allowed if shareholder owns directly or indirectly more than 50% of the outstanding stock. Capital gain treatment, to the extent applicable in the future, also disallowed in this circumstance. 7

8 H. Accumulated Earnings Tax (i) Additional tax imposed to penalize corporations for improperly accumulating income - i.e. circumvent double taxation. (ii) Additional tax of 27.5% of accumulated taxable income up to $100,000 and 38.5% of taxable income in excess of $100,000. (iii) First $250,000 of accumulated earnings is exempt. Some service corporations like law firms and accounting firms limited to a $150,000 exemption. (iv) Service allows accumulation for "active" purposes - e.g. expand business but not for "passive" purposes - buying minority shareholder s interest. (v) Real estate corporations can use excess earnings to reduce mortgage indebtedness. Real estate vulnerable to attack for investing earnings in other real estate because may be determined to be passive. I. Personal holding company (i) Discourage individuals from using corporation to avoid personal income taxes. Less likely today with individual tax rates lower than corporate rates. Tax for years beginning after July 1, 1987 is 28% of undistributed personal holding company income. (iii) Two tests for personal holding company: (b) 60% of corporation s adjusted gross ordinary income must be from passive sources; and 5 or fewer persons must own at least 50% of the stock during the last half of corporation s taxable year. (iv) Personal Holding Company income includes dividends, interest, rents, royalties, personal service contracts, etc. Rents excluded if they constitute 50% or more of the adjusted ordinary income of the corporation and if other personal holding 8

9 company income does not exceed 10% of the ordinary gross income of the corporation. J. Summarize Corporate Disadvantages. IV. THE CORPORATE ALTERNATIVE: THE S CORPORATION. A. Eligibility (6 requirements) (1) 35 or fewer shareholders (ii) no shareholders other than individuals, certain trusts and estates. (iii) no non-resident alien shareholders (iv) one class of stock (v) domestic corporation (vi) must not be an ineligible corporation as defined in 1361(b)(2). Ineligible corporations are members of an affiliated group, financial institutions to which 585 or 593 apply and various other non-eligible entities. B. ADVANTAGES SHARED WITH C CORPORATION. (i) Limited liability. (ii) Centralized management. (iii) Continuity of existence. (iv) Free transferability of shares subject to eligibility requirements. (v) Anonymity of shareholders. (vi) Income splitting between family members. (vii) Generally, profit sharing and other benefit plans can be in parity with C corporations. (viii) Separate taxpayer for dealer taint issues - but more likely to be attacked than a C corporation. C. ADVANTAGES NOT SHARED WITH C CORPORATION. (1) Timing of income and deductions: generally must be on a calendar year.

10 (b) exception: Natural business year test: 25% or more of corporation s receipts are recognized in last two months. (c) unlikely this will apply to Real Estate entities. (ii) Passive Loss Rules See Handout 3. S corporation not subject to passive loss limitations but shareholders of S corporation subject to rules on pass through. D. DISADVANTAGES OF C CORPORATION OVERCOME BY S CORPORATION. (i) Double Taxation. (b) generally, income taxed at shareholder level, no corporate level tax. exceptions if previously a C corporation. Not applicable to virgin S corporations: (1) Sting Tax on excess net passive income (only if C corporation prior to S corporation election). (2) Tax on built in gains during the ten year recognition period provided in TRA (3) Corporate alternative minimum tax on any preference items on built in gains. (4) Recapture of investment tax credit taken during a C corporation period. (ii) Inversion of Tax Rates Shareholders taxed at lower rate, 28% v. 34%. Repeal of General Utilities not applicable to "virgin" S corporations. Transitional rules for C corporations converted to S corporations - 10 year built in gain rule. (iv) Corporate Alternative Minimum Tax 10

11 (v) Generally not applicable at the corporate level. Losses generally pass through subject to basis requirements. (b) (C) basis is capital contribution plus loans directly to corporation from shareholders. Loans to corporation from third parties do not increase shareholders basis, even if shareholders personally guarantee. Note difference from partnership. Note example of real estate, borrowing and limitation on shareholder basis. (vi) Related party loss rules not applicable. (vii) Accumulated Earnings tax not applicable. (viii) Personal Holding Company Tax not applicable. E. S corporation Problems. (i) Not favorable in many instances because of basis problems. Particularly difficult for real estate syndications. (ii) Special allocations more difficult in S corporation because one class of stock. Some special allocations possible through salary guarantees. (iii) 35 shareholder limitation and other qualification limitations, i.e. - no corporate shareholders. (iv) Must have buy/sell or shareholder agreement to protect S corporation status. (v) Difficult to use S corporation with equity investors. (b) dry income problems. voting control problems. (vi) Inadvertent termination. (vii) 5 year delay for reelection. 11

12 V. HYBRID USE OF C CORPORATIONS A. Partnership Freeze (i) C corporation transfers some of its assets ("growth assets") to a partnership in return for a preferred partnership interest. (1) Partners can hold interests in partnership through one or more S corporations. (ii) Value of transferred assets must be exchanged for FMV of partnership interest. (1) Significant capital contribution by partners important to give economic substance on fixed return to C corporate partner. (2) Return to corporate partner should be cumulative. (iii) Freeze partnership, not C corporation, must control and manage growth assets. (iv) Freeze partnership must conduct business as a separate entity. (v) Probably must be general partnership Spreads liability and risk and gives significant business purpose. (vi) Partnership must be structured to have substantial economic effect. B. S Corporation Freeze (i) Corporation forms subsidiary ("Newco") transfers assets to Newco for all of Newco s stock. Corporation transfers all of Newco s stock to shareholders who then elect S corporation status. Need for a Ruling. (1) Must satisfy tax free spin off rules. 12

13 S (2) Newco s stock ownership may violate 1361(b) (2) (A) against membership in affiliated groups and 1361(b) (1) (B) concerning eligible S corporation shareholders. (3) Must have valid business purpose or service will not allow avoidance of general utilities repeal. (ii) Built in gain on appreciated assets for 10 years after Newco established. No worse than if C corporation elected to be a S corporation or used a partnership roll-out. C. For more details and greater discussion of Tax Risks see the August, 1988 publication of The Journal of Taxation", Using a Partnership Freeze to Shift Future Appreciation in Corporate Assets", by Bruce N. Lemons and Daniel R. Child. VI. CONCLUSION A. Type of entity used in real estate will depend on: (i) Type of real estate: (b) (C) purchase and sale. development. residential sales etc. B. Presumption: start with S corporation. (i) Consider corporate benefits after development, limited liability (b) centralized management (C) continuity of existence (d) free transferability of shares (e) anonymity of shareholders (f) assured tax status (g) tax free reorganizations (h) income splitting (between entities and family members) (1) separate taxpayer for dealer taint rules (j) no double tax (k) lower tax rates 13

14 (1) loss pass throughs (m) no general utilities problems (ii) Problems or disadvantages with S corporation. shareholder limitations (1) 35 shareholders (2) no corporate shareholders (3) no trust etc. shareholders (b) basis limitations (c) passive loss rules (d) special allocations C. Based on problems with S corporation consider partnership (i.e., shareholder limitations or basis problems), or C corporation (passive loss rules or shareholder limitations). 14

Willamette Management Associates

Willamette Management Associates Valuation Analyst Considerations in the C Corporation Conversion to Pass-Through Entity Tax Status Robert F. Reilly, CPA For a variety of economic and taxation reasons, this year may be a particularly

More information

Choosing the Right Entity for Maximum Tax Benefits for Your Construction Company

Choosing the Right Entity for Maximum Tax Benefits for Your Construction Company Choosing the Right Entity for Maximum Tax Benefits for Your Construction Company Timely re-evaluation of choice of entity will enhance the shareholder value of your contractor client By Theran J. Welsh

More information

DETERMINING THE BUSINESS ENTITY BEST FOR YOUR BUSINESS

DETERMINING THE BUSINESS ENTITY BEST FOR YOUR BUSINESS DETERMINING THE BUSINESS ENTITY BEST FOR YOUR BUSINESS 2015 Keith J. Kanouse One Boca Place, Suite 324 Atrium 2255 Glades Road Boca Raton, Florida 33431 Telephone: (561) 451-8090 Fax: (561) 451-8089 E-mail:

More information

Vertex Wealth Management LLC

Vertex Wealth Management LLC Vertex Wealth Management LLC Michael Aluotto President Private Wealth Manager 1325 Franklin Ave., Ste. 335 Garden City, NY 11530 516-294-8200 mjaluotto@1stallied.com S Corporation Page 1 of 7, see disclaimer

More information

S and C Corporations Create Different Tax Consequences

S and C Corporations Create Different Tax Consequences Tax information about corporate entities and strategies S and C Corporations Create Different Tax Consequences An S corporation is a pass-through tax entity, while a C corporation is a completely separate

More information

Considerations in the Health Care Company Tax Status Conversion from C Corporation to Pass-Through Entity

Considerations in the Health Care Company Tax Status Conversion from C Corporation to Pass-Through Entity Health Care Forensic Analysis Insights Considerations in the Health Care Company Tax Status Conversion from C Corporation to Pass-Through Entity Robert F. Reilly, CPA For a variety of economic and taxation

More information

The Business Organization: Choosing an Entity

The Business Organization: Choosing an Entity The Business Organization: Choosing an Entity The subject matter is divided into two sections: 1. Section A shows direct comparison of different types of organizational structures. 2. Section B details

More information

S Corporation Questions & Answers

S Corporation Questions & Answers S Corporation Questions & Answers Provisions in Chapter 173, P.L. 1993 provide that a corporation may elect to be treated as a New Jersey S corporation. The following is designed to address the most commonly

More information

Choice of Entity. Shareholders of publicly traded corporations can come and go with ease

Choice of Entity. Shareholders of publicly traded corporations can come and go with ease One of the most important decisions facing a new business owner is the selection of the most appropriate legal entity for their new business. There are several options including C Corporations, S Corporations,

More information

CORPORATE FORMATIONS AND CAPITAL STRUCTURE

CORPORATE FORMATIONS AND CAPITAL STRUCTURE 2 C H A P T E R CORPORATE FORMATIONS AND CAPITAL STRUCTURE LEARNING OBJECTIVES After studying this chapter, you should be able to 1 Explain the tax advantages and disadvantages of alternative business

More information

*Brackets adjusted for inflation in future years. 2015 Long Term Capital Gains & Dividends Taxable income up to $413,200/$457,600 0% - 15%*

*Brackets adjusted for inflation in future years. 2015 Long Term Capital Gains & Dividends Taxable income up to $413,200/$457,600 0% - 15%* Income Tax Planning Overview The American Taxpayer Relief Act of 2012 extended prior law for certain income tax rates; however, it also increased income tax rates on upper income earners. Specifically,

More information

Considering Alternatives to Liquidation

Considering Alternatives to Liquidation August, 2015 Considering Alternatives to Liquidation KNAV is a firm of International Accountants, Tax and Business Advisors. Presence in INDIA USA UK FRANCE NETHERLANDS SWITZERLAND CANADA E: admin@knavcpa.com

More information

L. IRC 501(c)(15) - SMALL INSURANCE COMPANIES OR ASSOCIATIONS

L. IRC 501(c)(15) - SMALL INSURANCE COMPANIES OR ASSOCIATIONS L. IRC 501(c)(15) - SMALL INSURANCE COMPANIES OR ASSOCIATIONS 1. Introduction The purpose of this section is to provide some background and an update in the area of IRC 501(c)(15) insurance companies or

More information

FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS

FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Chapter 10 FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Daniel Cassidy 1 10.1 INTRODUCTION Foreign companies with U.S. business transactions face various layers of taxation. These include income, sales,

More information

Current Trends in LLC and Partnership Tax Planning

Current Trends in LLC and Partnership Tax Planning INSIDE THE MINDS Current Trends in LLC and Partnership Tax Planning Leading LaU:Jers on Understanding the Imp,lications of Recent Legislation and Developing Effective Client Strategies ASPATORE ATRA and

More information

A Comparison of Entity Taxation

A Comparison of Entity Taxation A Comparison of Entity Taxation Sean W. Brewer, CPA Daniel N. Messing, CPA Pugh & Company, P.C. 315 N. Cedar Bluff Road; Suite 200 Knoxville, TN 37923 Sole Proprietorships Single Owner Advantages Easy

More information

S Corporation C Corporation Partnership. Company (LLC)

S Corporation C Corporation Partnership. Company (LLC) Description An LLC can only be formed by making appropriate filing with the state (see below). Owners are called members and the LLC may be managed by the members, similar to a partnership, or by managers

More information

U.S. Income Tax Return for an S Corporation

U.S. Income Tax Return for an S Corporation Form 1120S U.S. Income Tax Return for an S Corporation Do not file this form unless the corporation has filed or is attaching Form 2553 to elect to be an S corporation. Information about Form 1120S and

More information

Stock Options & Restricted Stock

Stock Options & Restricted Stock Stock Options & Restricted Stock By Charles A. Wry, Jr. mbbp.com Morse, Barnes-Brown & Pendleton, PC Waltham, MA Cambridge, MA mbbp.com Stock Options and Restricted Stock 3 I. Introduction Corporate equity

More information

New York State Corporate Tax Reform Outline Part A of Chapter 59 of the Laws of 2014 Signed March 31, 2014 April 2014

New York State Corporate Tax Reform Outline Part A of Chapter 59 of the Laws of 2014 Signed March 31, 2014 April 2014 Corporations Subject to [Bill 1 and 5; Law (TL) 209 unless otherwise noted] Unifies Articles 9-A (Corporate Franchise ) and 32 (Bank Franchise ). o Current Article 32 taxpayers are subject to the revised

More information

Chapter 18. Corporations: Distributions Not in Complete Liquidation. Eugene Willis, William H. Hoffman, Jr., David M. Maloney and William A.

Chapter 18. Corporations: Distributions Not in Complete Liquidation. Eugene Willis, William H. Hoffman, Jr., David M. Maloney and William A. Chapter 18 Corporations: Distributions Not in Complete Liquidation Eugene Willis, William H. Hoffman, Jr., David M. Maloney and William A. Raabe Copyright 2004 South-Western/Thomson Learning Taxable Dividends

More information

Basic Tax Issues in Choosing a Business Entity 2015

Basic Tax Issues in Choosing a Business Entity 2015 Basic Tax Issues in Choosing a Business Entity 2015 By Robert M. Finkel and Diana C. Española mbbp.com Corporate IP Licensing & Strategic Alliances Employment & Immigration Taxation Litigation 781-622-5930

More information

A person. who wants BACKGROUND. corporation. corporation. action, the. The C corporation. subject to. qualify to make. or certain

A person. who wants BACKGROUND. corporation. corporation. action, the. The C corporation. subject to. qualify to make. or certain CHOOSING THE FORM OF BUSINESS ORGANIZATION A person who wants to start a business can choose from a variety of different types of business entity formations. For instance, a person can form a business

More information

SCORE SAS 64 Sponsored by U. S. Small Business Administration ORANGE COUNTY CHAPTER 114, (714) 550-7369 www.score114.org

SCORE SAS 64 Sponsored by U. S. Small Business Administration ORANGE COUNTY CHAPTER 114, (714) 550-7369 www.score114.org SCORE SAS 64 Sponsored by U. S. Small Business Administration ORANGE COUNTY CHAPTER 114, (714) 550-7369 www.score114.org The subject matter is divided into two sections: THE BUSINESS ORGANIZATION CHOOSING

More information

SHOULD MY BUSINESS BE AN S CORPORATION OR A LIMITED LIABILITY COMPANY?

SHOULD MY BUSINESS BE AN S CORPORATION OR A LIMITED LIABILITY COMPANY? SHOULD MY BUSINESS BE AN S CORPORATION OR A LIMITED LIABILITY COMPANY? 2015 Keith J. Kanouse One Boca Place, Suite 324 Atrium 2255 Glades Road Boca Raton, Florida 33431 Telephone: (561) 451-8090 Fax: (561)

More information

The 3.8% Medicare Surtax on Investment Income

The 3.8% Medicare Surtax on Investment Income Wealth Strategy Report The 3.8% Medicare Surtax on Investment Income OVERVIEW Beginning in 2013, certain investment income will be subject to an additional 3.8% surtax, enacted as part of the Health Care

More information

IN THIS ISSUE: July, 2011 j Income Tax Planning Concepts in Estate Planning

IN THIS ISSUE: July, 2011 j Income Tax Planning Concepts in Estate Planning IN THIS ISSUE: Goals of Income Tax Planning Basic Estate Planning Has No Income Tax Impact Advanced Estate Planning Can Have Income Tax Implications Taxation of Corporations, LLCs, Partnerships and Non-

More information

NAR Frequently Asked Questions Health Insurance Reform

NAR Frequently Asked Questions Health Insurance Reform NEW MEDICARE TAX ON UNEARNED NET INVESTMENT INCOME Q-1: Who will be subject to the new taxes imposed in the health legislation? A: A new 3.8% tax will apply to the unearned income of High Income taxpayers.

More information

Objectives. Discuss S corp fringe benefits.

Objectives. Discuss S corp fringe benefits. S Corporations Objectives Define an S corp. Identify the benefits of being an S corp. Determine how an entity elects to be an S corp. Establish how an S corp is taxed. Describe the S corp shareholder s

More information

Choice of Entity: Corporation or Limited Liability Company?

Choice of Entity: Corporation or Limited Liability Company? March 2014 Choice of Entity: Corporation or Limited Liability Company? By Gianfranco A. Pietrafesa* Attorney at Law There are many different types of business entities, including corporations, general

More information

Module 10 S Corporation/Corporation Study Guide Introduction

Module 10 S Corporation/Corporation Study Guide Introduction Module 10 Study Guide Introduction Running your own business presents many challenges. One of the most difficult is complying with complex and ever-changing tax laws. This small-business tax education

More information

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax USA Taxation FUNDS AND FUND MANAGEMENT 2010 3.1 Taxation of funds Taxation of regulated investment companies: income tax Investment companies in the United States (US) are structured either as openend

More information

U.S. Taxation of Foreign Investors

U.S. Taxation of Foreign Investors U.S. Taxation of Foreign Investors By Richard S. Lehman & Associates Attorneys at Law Copyright 2004 Copyright by Richard S. Lehman Page 1 U.S. Taxation of Foreign Corporations And Nonresident Aliens General

More information

When Acquirer or Target is Spelled with an S Special Considerations for S Corporations in Mergers and Acquisitions. C. Wells Hall January 25, 2007

When Acquirer or Target is Spelled with an S Special Considerations for S Corporations in Mergers and Acquisitions. C. Wells Hall January 25, 2007 When Acquirer or Target is Spelled with an S Special Considerations for S Corporations in Mergers and Acquisitions C. Wells Hall January 25, 2007 40160935 IRS CIRCULAR 230 NOTICE. Any advice expressed

More information

The S-Corporation Election; Advantages & Disadvantages

The S-Corporation Election; Advantages & Disadvantages The S-Corporation Election; Advantages & Disadvantages Presented by: National Society of Accountants 1010 N. Fairfax Street Alexandria, VA 22314 800-966-6679 www.nsacct.org 1 Learning Objectives At the

More information

Non-Financial Assets Tax and Other Special Rules

Non-Financial Assets Tax and Other Special Rules Wealth Strategy Report Non-Financial Assets Tax and Other Special Rules OVERVIEW Because unique attributes distinguish them from other asset classes, nonfinancial assets may offer you valuable financial

More information

Presentation for. CSEA IRS/Practitioner Fall Seminars. S Corporation. Darrell Early, IRS. Date September 27, 2012

Presentation for. CSEA IRS/Practitioner Fall Seminars. S Corporation. Darrell Early, IRS. Date September 27, 2012 Presentation for CSEA IRS/Practitioner Fall Seminars S Corporation Darrell Early, IRS Date September 27, 2012 Agenda What is an S Corporation? Why would a Corporation make the S election? How does a Corporation

More information

WithumSmith+Brown, PC Certified Public Accountants and Consultants BE IN A POSITION OF STRENGTH. withum.com

WithumSmith+Brown, PC Certified Public Accountants and Consultants BE IN A POSITION OF STRENGTH. withum.com 1 Objectives for Today s Webinar What are the different types of K-1s? K-1 line items where do they end up? My income is greater than the cash I received why would that be? 2 What is a Schedule K-1 Form?

More information

The Lifetime Capital Gains Exemption

The Lifetime Capital Gains Exemption The Lifetime Capital Gains Exemption Introduction This Tax Topic briefly reviews the rules contained in section 110.6 of the Income Tax Act (the "Act") concerning the lifetime capital gains exemption and

More information

Choice of Business Entities

Choice of Business Entities Choice of Business Entities In order to carry on a trade or business, a type of business entity must be chosen. For all practical purposes, the four major business entities for the current 2000 year are:

More information

Avoiding U.S. Investment Tax Traps

Avoiding U.S. Investment Tax Traps Avoiding U.S. Investment Tax Traps Structuring Real Estate and Other Fund Investments Presented by: Joseph Gulant and Daniel Blickman Major Categories of Tax to Consider in Planning International Transactions

More information

SC REVENUE RULING #06-12. All previous advisory opinions and any oral directives in conflict herewith.

SC REVENUE RULING #06-12. All previous advisory opinions and any oral directives in conflict herewith. State of South Carolina Department of Revenue 301 Gervais Street, P. O. Box 125, Columbia, South Carolina 29214 Website Address: http://www.sctax.org SC REVENUE RULING #06-12 SUBJECT: Tax Rate Reduction

More information

tax planning strategies

tax planning strategies tax planning strategies In addition to saving income taxes for the current and future years, tax planning can reduce eventual estate taxes, maximize the amount of funds you will have available for retirement,

More information

Sneak Preview. Real Estate Accounting & Taxation. Included in this preview: Copyright Page Table of Contents Excerpt of Chapter 1

Sneak Preview. Real Estate Accounting & Taxation. Included in this preview: Copyright Page Table of Contents Excerpt of Chapter 1 Sneak Preview Real Estate Accounting & Taxation By John F. Mahoney, CPA Included in this preview: Copyright Page Table of Contents Excerpt of Chapter 1 For additional information on adopting this book

More information

CHOICE OF BUSINESS ENTITY

CHOICE OF BUSINESS ENTITY CHOICE OF BUSINESS ENTITY Presented by James M. Jimenez, Esq. Pacific Business Law Group A Professional Corporation 1601 Cloverfield Boulevard Suite 200 South Tower Santa Monica, California 90401 July

More information

S Corporations General Overview

S Corporations General Overview S Corporations General Overview Richard Furlong Jr. Senior Stakeholder Liaison Define an S Corp An "S corporation" is a an entity that qualifies as a small business corporation that has an S election in

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 200750009 Release Date: 12/14/2007 Index Numbers: 368.04-00, 355.01-00 ---------------------- -------------------------------------------------- --------------------------------------

More information

Choice of Entity. Paul E. Costantino, CPA, MST Costantino Richards Rizzo, LLP, Wakefield

Choice of Entity. Paul E. Costantino, CPA, MST Costantino Richards Rizzo, LLP, Wakefield Choice of Entity Paul E. Costantino, CPA, MST Costantino Richards Rizzo, LLP, Wakefield I. Overview of Entities The entity selection process is one of the first steps in the formation of any business,

More information

New Legislation Enhances the Benefits of a Section 1042 Tax-Deferred Sale

New Legislation Enhances the Benefits of a Section 1042 Tax-Deferred Sale ESOP Transaction Insights New Legislation Enhances the Benefits of a Section 1042 Tax-Deferred Sale Michael R. Holzman, Esq., and Christopher T. Horner II, Esq. Recent legislation increased the income

More information

Income Tax Considerations for Trusts and Estates: Avoiding the New Income Taxes. By: Robert Barnett CPA, JD, MS (Taxation)

Income Tax Considerations for Trusts and Estates: Avoiding the New Income Taxes. By: Robert Barnett CPA, JD, MS (Taxation) Income Tax Considerations for Trusts and Estates: Avoiding the New Income Taxes By: Robert Barnett CPA, JD, MS (Taxation) I. The Importance of Trust and Estate Taxes Today a. The trust is recognized as

More information

American Taxpayer Relief Act of 2012- UPDATED

American Taxpayer Relief Act of 2012- UPDATED American Taxpayer Relief Act of 2012- UPDATED On January 2, 2013, the President signed the American Taxpayer Relief Act, thus ending the nation s brief stint over the fiscal cliff a confluence of expiring

More information

United States Corporate Income Tax Summary

United States Corporate Income Tax Summary United States Corporate Income Tax Summary SECTION 1: AT A GLANCE CliftonLarsonAllen LLP 222 Main Street, PO Box 1347 Racine, WI 53401 262-637-9351 fax 262-637-0734 www.cliftonlarsonallen.com Corporate

More information

THE FEDERAL LOW-INCOME HOUSING TAX CREDIT AND HISTORIC REHABILITATION TAX CREDIT

THE FEDERAL LOW-INCOME HOUSING TAX CREDIT AND HISTORIC REHABILITATION TAX CREDIT THE FEDERAL LOW-INCOME HOUSING TAX CREDIT AND HISTORIC REHABILITATION TAX CREDIT This outline provides an overview of the federal low-income housing tax credit and historic rehabilitation tax credit. I.

More information

U.S. Corporation Income Tax Return For calendar year 2015 or tax year beginning, 2015, ending, 20

U.S. Corporation Income Tax Return For calendar year 2015 or tax year beginning, 2015, ending, 20 Form 1120 Department of the Treasury Internal Revenue Service A Check if: 1a Consolidated return (attach Form 851). b Life/nonlife consolidated return... 2 Personal holding co. (attach Sch. PH).. 3 Personal

More information

INVESTMENT HOLDING COMPANIES

INVESTMENT HOLDING COMPANIES INVESTMENT HOLDING COMPANIES > RBC DOMINION SECURITIES INC. FINANCIAL PLANNING PUBLICATIONS At RBC Dominion Securities Inc., we have been helping clients achieve their financial goals since 1901. Today,

More information

1/5/2016. S Corporations. Objectives. Define an S Corp

1/5/2016. S Corporations. Objectives. Define an S Corp S Corporations Objectives Define an S corp. Identify the benefits of being an S corp. Determine how an entity elects to be an S corp. Establish how an S corp is taxed. Describe the S corp shareholder s

More information

CHOICE OF ENTITY CONSIDERATIONS. A Basic Guide to Entrepreneurs. October 9, 2012

CHOICE OF ENTITY CONSIDERATIONS. A Basic Guide to Entrepreneurs. October 9, 2012 CHOICE OF ENTITY CONSIDERATIONS A Basic Guide to Entrepreneurs October 9, 2012 Bill Osterbrock, Of Counsel Baker Donelson wosterbrock@bakerdonelson.com 404-589-3418 Iliana Malinov, Tax Manager HLB Gross

More information

Instructions for Form 8582 Passive Activity Loss Limitations

Instructions for Form 8582 Passive Activity Loss Limitations 2007 Instructions for Form 8582 Passive Activity Loss Limitations Department of the Treasury Internal Revenue Service Section references are to the Internal rental passive activities. Overall loss is limited,

More information

The goal today is to accomplish three things:

The goal today is to accomplish three things: MARK SHERMAN, CPA The goal today is to accomplish three things: 1. Educate you on The Mortgage Forgiveness Debt Relief Act of 2007. 2. Show you how to save taxes on your real estate business. 3. Help you

More information

Types of Business. Part II S Corporations and LLCs

Types of Business. Part II S Corporations and LLCs Types of Business Part II S Corporations and LLCs Student Learning Objectives Describe features of the alternative forms of ownership such as S corporations and limited liability company. Alternative Forms

More information

Estate Planning and Income Tax Issues for Nonresident Aliens Owning US Real Estate

Estate Planning and Income Tax Issues for Nonresident Aliens Owning US Real Estate Estate Planning and Income Tax Issues for Nonresident Aliens Owning US Real Estate 1. Introductory Matters. Presented by Paul McCawley Greenberg Traurig, P.A. mccawleyp@gtlaw.com 954.768.8269 October 24,

More information

INTERNATIONAL TIDBIT: Reporting Foreign Investments New Requirements for the 2013 Tax Year

INTERNATIONAL TIDBIT: Reporting Foreign Investments New Requirements for the 2013 Tax Year INTERNATIONAL TIDBIT: Reporting Foreign Investments New Requirements for the 2013 Tax Year The last few years have seen increased emphasis on individuals reporting about their foreign investments and penalizing

More information

PRESENT LAW AND HISTORICAL OVERVIEW OF THE FEDERAL TAX SYSTEM

PRESENT LAW AND HISTORICAL OVERVIEW OF THE FEDERAL TAX SYSTEM PRESENT LAW AND HISTORICAL OVERVIEW OF THE FEDERAL TAX SYSTEM Scheduled for a Public Hearing Before the COMMITTEE ON WAYS AND MEANS on January 20, 2011 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION

More information

TAX INFORMATION RELEASE NO. 99-4

TAX INFORMATION RELEASE NO. 99-4 BENJAMIN J. CAYETANO GOVERNOR MAZIE HIRONO LT. GOVERNOR RAY K. KAMIKAWA DIRECTOR OF TAXATION MARIE Y. OKAMURA DEPUTY DIRECTOR Tel: (808) 587-1540 Fax: (808) 587-1560 STATE OF HAWAII DEPARTMENT OF TAXATION

More information

By: Philip J. Clements and Cassie Glynn. October 2011

By: Philip J. Clements and Cassie Glynn. October 2011 C TO S TAX CONVERSION By: Philip J. Clements and Cassie Glynn Fundamental Tax Planning Principles: October 2011 General Principles: When everything is done, you should find that income or gains are taxed

More information

Business Types and Payroll Taxes

Business Types and Payroll Taxes Minority Business Development Division (MBDD) Prince George s County Office of Central Services Legal Issues and Taxes Facing Small and Minority Businesses October 26, 2010 Business Types and Payroll Taxes

More information

Choice of Entity: Corporation or Limited Liability Company?

Choice of Entity: Corporation or Limited Liability Company? September 2012 Choice of Entity: Corporation or Limited Liability Company? By Gianfranco A. Pietrafesa* Attorney at Law There are many different types of business entities, including corporations, general

More information

Foreign Person Investing in U.S. Real Estate

Foreign Person Investing in U.S. Real Estate Foreign Person Investing in U.S. Real Estate Ian Shane Golenbock Eiseman Assor Bell & Peskoe LLP TTN New York Conference 2013 Foreign Purchases of U.S. Homes Foreign Home Buyers want to: Minimize tax on

More information

Business Organization\Tax Structure

Business Organization\Tax Structure Business Organization\Tax Structure Kansas Secretary of State s Office Business Services Division First Floor, Memorial Hall 120 S.W. 10th Avenue Topeka, KS 66612-1594 Phone: (785) 296-4564 Fax: (785)

More information

Presentation of Income and Deductions

Presentation of Income and Deductions TAXATION OF S CORPORATIONS Accounting 551T - Lecture 8 Schlesinger: Chapters 6-8 Robert A. Scharlach Presentation of Income and Deductions Two Categories Separately stated items Non-separately stated items

More information

KMP / EPB Summary Tax Information Package

KMP / EPB Summary Tax Information Package KMP / EPB Summary Tax Information Package Kinder Morgan, Inc. (KMI) has entered into agreements to acquire all of the equity interests of Kinder Morgan Energy Partners, L.P. (KMP) El Paso Pipeline Partners,

More information

Michigan Business Tax Frequently Asked Questions

Michigan Business Tax Frequently Asked Questions NOTICE: The MBT was amended by 145 PA 2007 on December 1, 2007. Act 145 imposes an annual surcharge to taxpayers' MBT liability, as well as makes other changes. Some of the FAQs below have revised answers

More information

CANADIAN CORPORATE TAXATION. A General Guide January 31, 2011 TABLE OF CONTENTS INCORPORATION OF A BUSINESS 1 POTENTIAL ADVANTAGES OF INCORPORATION 1

CANADIAN CORPORATE TAXATION. A General Guide January 31, 2011 TABLE OF CONTENTS INCORPORATION OF A BUSINESS 1 POTENTIAL ADVANTAGES OF INCORPORATION 1 CANADIAN CORPORATE TAXATION A General Guide January 31, 2011 TABLE OF CONTENTS PART A PAGE INCORPORATION OF A BUSINESS 1 POTENTIAL ADVANTAGES OF INCORPORATION 1 POTENTIAL DISADVANTAGES OF INCORPORATION

More information

TO: OUR FRIENDS AND PROSPECTIVE CLIENTS FROM: THOMAS WILLIAMS, CPA RE: U.S. INCOME TAX ISSUES OF FOREIGN NATIONALS DATE: AS OF JANUARY 1, 2010

TO: OUR FRIENDS AND PROSPECTIVE CLIENTS FROM: THOMAS WILLIAMS, CPA RE: U.S. INCOME TAX ISSUES OF FOREIGN NATIONALS DATE: AS OF JANUARY 1, 2010 THOMAS WILLIAMS CPA, PLLC TO: OUR FRIENDS AND PROSPECTIVE CLIENTS FROM: THOMAS WILLIAMS, CPA RE: U.S. INCOME TAX ISSUES OF FOREIGN NATIONALS DATE: AS OF JANUARY 1, 2010 Dear Friends: The following is an

More information

Understanding the taxability of investments

Understanding the taxability of investments Understanding the taxability of investments Managing your portfolio to help control your tax bill Investors need to consider many factors in the process of choosing investments. One at the top of many

More information

ENTITY CHOICE AND EFFECTIVE TAX RATES

ENTITY CHOICE AND EFFECTIVE TAX RATES ENTITY CHOICE AND EFFECTIVE TAX RATES Prepared by Quantria Strategies, LLC for the National Federation of Independent Business and the S Corporation Association ENTITY CHOICE AND EFFECTIVE TAX RATES CONTENTS

More information

Tax Consequences of Providing IT Consulting Services

Tax Consequences of Providing IT Consulting Services Tax Consequences of Providing IT Consulting Services Presented By:, CA, CPA And Offices in Toronto & Chicago 1-888- US TAXES Canadian IT Contractors Can Work: As employees; Pros & Cons of Being an Employee

More information

OVERVIEW OF THE FEDERAL TAX SYSTEM AS IN EFFECT FOR 2013

OVERVIEW OF THE FEDERAL TAX SYSTEM AS IN EFFECT FOR 2013 OVERVIEW OF THE FEDERAL TAX SYSTEM AS IN EFFECT FOR 2013 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION January 8, 2013 JCX-2-13 CONTENTS Page INTRODUCTION... 1 I. SUMMARY OF PRESENT-LAW FEDERAL

More information

Partner's Instructions for Schedule K-1 (Form 1065)

Partner's Instructions for Schedule K-1 (Form 1065) 2014 Partner's Instructions for Schedule K-1 (Form 1065) Partner's Share of Income, Deductions, Credits, etc. (For Partner's Use Only) Department of the Treasury Internal Revenue Service Section references

More information

tax planning strategies

tax planning strategies tax planning strategies In addition to saving income taxes for the current and future years, effective tax planning can reduce eventual estate taxes, maximize the amount of funds you will have available

More information

Different Types of Corporations: Advantages/ Disadvantages of Corporations

Different Types of Corporations: Advantages/ Disadvantages of Corporations Different Types of Corporations: Advantages/ Disadvantages of Corporations Article published at: http://www.morebusiness.com/getting_started/incorporating/d934832501.brc Anyone who operates a business,

More information

2010 Partner s Instructions for Schedule K-1 (Form 1065) Partner s Share of Income, Deductions, Credits, etc. (For Partner s Use Only)

2010 Partner s Instructions for Schedule K-1 (Form 1065) Partner s Share of Income, Deductions, Credits, etc. (For Partner s Use Only) 2010 Partner s Instructions for Schedule K-1 (Form 1065) Partner s Share of Income, Deductions, Credits, etc. (For Partner s Use Only) Section references are to the Internal Revenue Code unless otherwise

More information

How do the 2016 Presidential Tax Plans Compare So Far?

How do the 2016 Presidential Tax Plans Compare So Far? How do the 2016 Presidential Tax Plans Compare So Far? 10-Year GDP Growth 10.0% 16.0% -1.0% 13.9% 15.0% -9.5% 11.5% 10-Year Capital Investment Growth 28.8% 46.6% -2.8% 43.9% 48.9% -18.6% 29% 10-Year Wage

More information

Termination of S Corporations and of S Shareholder Interests

Termination of S Corporations and of S Shareholder Interests College of William & Mary Law School William & Mary Law School Scholarship Repository William & Mary Annual Tax Conference Conferences, Events, and Lectures 1988 Termination of S Corporations and of S

More information

SPDR Wells Fargo Preferred Stock ETF

SPDR Wells Fargo Preferred Stock ETF SPDR Wells Fargo Preferred Stock ETF Summary Prospectus-October 31, 2015 PSK (NYSE Ticker) Before you invest in the SPDR Wells Fargo Preferred Stock ETF (the Fund ), you may want to review the Fund's prospectus

More information

New 3.8% "Affordable Care Act" Tax May Burden Some S Corporation Shareholders

New 3.8% Affordable Care Act Tax May Burden Some S Corporation Shareholders New 3.8% "Affordable Care Act" Tax May Burden Some S Corporation Shareholders Prepared By: The Tax Group Written By: Ivan H. Golden Co-author: Robert R. Pluth Jr. Electing small business trusts ( ESBTs

More information

A partnership having one or more general partners and one or more limited partners.

A partnership having one or more general partners and one or more limited partners. 1. Definition A business association of two or more persons to conduct a business unless formed under any other statute. A partnership having one or more general partners and one or more limited partners.

More information

Taking a Second Bite of the 3.8% Medicare Surtax Apple: Considerations for Real Estate Investors and Developers

Taking a Second Bite of the 3.8% Medicare Surtax Apple: Considerations for Real Estate Investors and Developers FICPA Gulf Coast Chapter February 3, 2015 Taking a Second Bite of the 3.8% Medicare Surtax Apple: Considerations for Real Estate Investors and Developers E. John Wagner, II 200 South Orange Avenue Sarasota

More information

capital gains and dividend income

capital gains and dividend income capital gains and dividend income Managing capital gains and losses can help you save taxes, defer taxes and obtain the highest after-tax yield on your assets. Since the tax rate on short-term capital

More information

Crunch or Crucible? Upcoming Changes in the Federal Tax Law A Special Edition Tax Guide for Friends and Alumni of Pomona College

Crunch or Crucible? Upcoming Changes in the Federal Tax Law A Special Edition Tax Guide for Friends and Alumni of Pomona College Upcoming Changes in the Federal Tax Law A Special Edition Tax Guide for Friends and Alumni of Pomona College Pomona College, Office of Trusts & Estates, 550 N. College Ave., Claremont, CA 91711 www.pomona.planyourlegacy.org

More information

Non-Deductible/ROTH IRA Disclosure Statement

Non-Deductible/ROTH IRA Disclosure Statement UBS Trust Company of Puerto Rico Non-Deductible/ROTH IRA Disclosure Statement UBS Trust Company of Puerto Rico ( UBS Trust or the Trustee ), as trustee of the UBS Puerto Rico Non- Deductible/ ROTH Individual

More information

Limited Liability Company (LLC)

Limited Liability Company (LLC) Vertex Wealth Management LLC Michael Aluotto President Private Wealth Manager 1325 Franklin Ave., Ste. 335 Garden City, NY 11530 516-294-8200 mjaluotto@1stallied.com Limited Liability Company (LLC) Page

More information

timing is everything One issue in an array of decisions involving capital Taxes TAX PLANNING FOR CAPITAL ASSET DISPOSAL IS COMPLEX YET NECESSARY.

timing is everything One issue in an array of decisions involving capital Taxes TAX PLANNING FOR CAPITAL ASSET DISPOSAL IS COMPLEX YET NECESSARY. timing is everything Taxes TAX PLANNING FOR CAPITAL ASSET DISPOSAL IS COMPLEX YET NECESSARY. B Y D A VID J OY, C PA ; S TEPHEN C. DEL V ECCHIO, C PA ; B. DOUGLAS C LINTON, C PA ; AND J AMES C. YOUNG, C

More information

Basic Tax Issues in Acquisition Transactions

Basic Tax Issues in Acquisition Transactions Basic Tax Issues in Acquisition Transactions Michael L. Schler 1 Table of Contents I. INTRODUCTION... 880 II. TAXABLE OR TAX-FREE TRANSACTION?... 882 A. Is a Tax-Free Reorganization Possible?... 882 B.

More information

PRESENT LAW AND HISTORICAL OVERVIEW OF THE FEDERAL TAX SYSTEM

PRESENT LAW AND HISTORICAL OVERVIEW OF THE FEDERAL TAX SYSTEM PRESENT LAW AND HISTORICAL OVERVIEW OF THE FEDERAL TAX SYSTEM Scheduled for a Public Hearing Before the SENATE COMMITTEE ON FINANCE on December 2, 2010 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION

More information

S Corporation Update. Charles E. Marston, CPA, MST Tax Principal, S.R. Snodgrass, P.C. cmarston@srsnodgrass.com

S Corporation Update. Charles E. Marston, CPA, MST Tax Principal, S.R. Snodgrass, P.C. cmarston@srsnodgrass.com Charles E. Marston, CPA, MST Tax Principal, S.R. Snodgrass, P.C. cmarston@srsnodgrass.com Agenda I. S Corp basics overview II. What s new? Late election relief NII tax Reasonable comp/sh loans Self employment

More information

LIMITED LIABILITY COMPANIES

LIMITED LIABILITY COMPANIES LIMITED LIABILITY COMPANIES AGRICULTURAL APPLICATIONS PRESENTED BY KENT B MILLER EXTENSION AG ECONOMIST KS FARM MGT ASSOC SE 103 ½ E. 9 TH, SUITE 202 WINFIELD, KS 67156-2858 620-221-6906 kentfmse@yahoo.com

More information

H.R. 3970 Tax Reduction and Reform Act of 2007

H.R. 3970 Tax Reduction and Reform Act of 2007 H.R. 3970 Tax Reduction and Reform Act of 2007 I. INDIVIDUAL TAX RELIEF October 29, 2007 The combination of the general tax reductions below and full repeal of the individual alternative minimum tax (AMT)

More information

INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM December 12, 2002

INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM December 12, 2002 Number: 200330002 Release Date: 7/25/2003 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM December 12, 2002 Index (UIL) No.: CASE MIS No.: 0812.00-00 TAM-144382-02/CC:FIP:B4 Taxpayer's

More information

Instructions for Form 8938

Instructions for Form 8938 2015 Instructions for Form 8938 Statement of Specified Foreign Financial Assets Department of the Treasury Internal Revenue Service Section references are to the Internal Revenue Code unless otherwise

More information