S Corporations: QSUB Elections

Description

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). This course will examine the tax compliance requirements necessary to successfully make the QSUB election.

Highlights

• Requirements that must be satisfied to make the QSUB election.
• How to make the QSUB election.
• Immediate tax consequences of 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.

Objectives

• 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.

Designed For

CPAs and lawyers.