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.

Public Finance Activities, Corporate Income Taxes, Evaluation, Tax elections

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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).

United States. Internal Revenue Service, Liquidation

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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.

Administration of General Economic Programs, Taxes, Export Promotion, Taxation, Foreign trade promotion, Domestic international sales corporations

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