Choice of business entity after JGTRRA
Article Abstract:
When C Corporation income was taxed at corporate rates and distributed at ordinary rates, small business owner's choice of business entity was based on what was thought as the most likely scenario. Post passing of the Jobs and Growth Tax Reconciliation Act of 2003, the possibility that all income earned by a C Corporation owner will be taxed at no more than 15 percent of a rate by splitting the income three ways is a luxury, not available to pass-thru owners.
Publication Name: Business Entities
Subject: Business
ISSN: 1524-3583
Year: 2004
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Corporations - Partial liquidation treatment for distribution derived from liquidation of subsidiary after sale of subsidiary's business
Article Abstract:
The IRS in the Ltr.Rul. 200445009 has ruled that proceeds from the sale of subsidiary's business that were transferred to the parent company which thereafter distributed stock on a pro-rata redemption of Parent company stock, qualifies as partial liquidation of Parent under Section 302(b) (4).
Publication Name: Business Entities
Subject: Business
ISSN: 1524-3583
Year: 2005
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IC DISCs
Article Abstract:
The Interest Charge Domestic International Sales Corporation provisions and the tax benefits it offers to the company and its shareholders are discussed. The methods to avail the benefits are also explained.
Publication Name: Business Entities
Subject: Business
ISSN: 1524-3583
Year: 2004
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