Consider the factors that determine whether a QSUB election should be made. Discuss topics covering both immediate and long-term tax consequences and the process necessary to make the election. If an S corporation owns 100% of the stock of another corporation, the tax consequences of the operation of the subsidiary will depend on whether the S corporation makes a ‘qualified subchapter S subsidiary election’ (QSUB election). We’ll examine the tax compliance requirements necessary to successfully make the QSUB election.
• Recognize the immediate and long-term tax consequences of making or not making a QSUB election.
• Identify situations where the QSUB election can be made.
• Analyze the result of the “deemed liquidation” including unusual facts which can create complications.
• Discuss situations where the election could be desirable or undesirable.
• Explain the tax compliance requirements necessary to successfully make the QSUB election.
• Understand tax consequences of termination of QSUB election
• Requirements that must be satisfied to make the QSUB election.
• How to make the QSUB election.
• Immediate tax consequences of the election, “deemed liquidation.”
• Potential complications of “deemed IRC 332 liquidation.”
• Situations where the QSUB election could be desirable.
• Situations where the QSUB election could be undesirable.
• Longer-term consequences of the decision to elect or not elect.
• Terminations of QSUB election
CPAs and Lawyers.
Understanding the basics of the taxation of corporations, and S corporations.
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