Identify and discuss various tax planning opportunities related to the operation of a corporate business with an S corporation election. Topics range from annual recurring planning to unusual transactions, such as stock redemptions and the sale of the corporate business.
Learning Objectives
• Understanding the tax consequences of making the S corporation election to the corporation and shareholders
• Understanding how to plan to minimize the impact of the loss limitation rules
• Determining the tax considerations related to buying or selling an S corporation
• Identifying tax planning opportunities at the death of the shareholder of an S corporation
Major Topics
• Overview of the taxation of corporations and shareholder including making the S corporation election
• The decision to elect S corporation status—factors to consider
• Explanation and analysis of the application of the "qualified business income deduction (IRC 199A)
• Self-employment tax and S corporations
• Distribution tax planning
• Planning to minimize the impact of loss limitations
• Tax planning for years with both distributions and losses
• Termination Planning
• Tax planning regarding the transfer of appreciated assets to an S corporation
• Buying and selling S corporations—tax planning ideas
• Tax considerations of using the QSUB, Section 338(h)(10), or 336(e) elections
• Tax Issues to consider at the death of S corporation shareholder
• Stock redemptions as a tax planning tool
• Accommodating a "non-qualified" investor
• Trusts and tax-exempt exempt shareholders
• The second class of stock risks
• S corporation election compared to Section 1202 stock incentive