D’Avico, Stalls & Decker: Converting from S corp. to C corp.: Select issues for consideration

T. Christopher D’Avico, Lauren Pope Stalls, and Ed Decker have published their article, Converting from S corp. to C corp.: Select issues for consideration in the AICPA Tax Advisor. Their article begins as follows:

The recent passage of comprehensive federal tax reform (see the law formerly titled the Tax Cuts and Jobs Act of 2017, P.L. 115-97) has taxpayers of all types evaluating the impact of the new rules on their current tax positions. For example, S corporations may be considering whether it may be more advantageous to be taxed as a C corporation, despite the double taxation of C corporation dividend distributions. S corporations that perform this analysis and conclude that it may be more advantageous to be taxed as a C corporation should consider, among others, the following issues.

The article proceeds to address the following topics:

  • revoking an s election
  • income allocations for midyear revocations
  • tax accounting considerations
  • subsidiaries
  • distributions following a revocation
  • requirement that “money” be distributed
  • suspended shareholder losses at the time of revocation
  • closing thoughts

See full article by clicking here. 

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.

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