Hazards in Electing S Corporation Status After a Merger

Date
2007-02-02
Authors
Harl, Neil
Major Professor
Advisor
Committee Member
Journal Title
Journal ISSN
Volume Title
Publisher
Altmetrics
Authors
Research Projects
Organizational Units
Journal Issue
Series
Department
Iowa State University Digital Repository
Abstract

The potential for triggering painful income tax liabilities from the “built-in gains” tax1 upon shifting from C corporation status to S corporation status is well known.2 The built-in gains tax is imposed in an effort to thwart attempts by C corporations to elect S corporation status to minimize the effects of the modification of the corporate liquidation rules in the 1986 Act. However, a recent private letter ruling has focused attention on the imposition of the built-in gains tax in the event of a merger without regard to the date of the corporation’s election to be an S corporation.3

Comments
Description
Keywords
Citation
DOI
Source
Collections