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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.

Author: Walker, Arthur C., Jr.
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
Methods, Tax planning, S corporations

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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.

Author: Gallagher, Patrick C.
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1999
Usage, Limited liability companies, Partnership, Partnerships

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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.

Author: Misey, Robert J., Jr.
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1999
Analysis, Laws, regulations and rules, Tax administration and procedure, Tax administration, Transfer pricing

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Subjects list: United States, Planning, Taxation, Tax law, Tax accounting, Subsidiary corporations, Subsidiaries, Affiliated corporations
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