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.
- Understand the application of the "qualified business income" deduction ( IRC 199A).
- Determining the tax costs and benefits of making or terminating the S corporation election.
- Identifying self-employment / FICA - Medicare tax planning opportunities.
- Understanding how to plan to minimize the impact of the loss limitation rules.
- Identifying tax planning opportunities in years with losses and distributions.
- Understanding tax planning ideas when the S election is terminated.
- Determining the tax considerations related to buying or selling an S corporation.
- Determining when to make the QSUB, Section 338(h)(10), or 336(e) elections.
- Identifying tax planning opportunities at the death of the shareholder of an S corporation.
- Recall ideas to accommodate a "non-qualified" investor.
- Understanding the law related to trusts and tax-exempt shareholders including ESOP's.
- To be able to evaluate the risk of disqualification based on the second class of stock.
- S corporation election compared to the Section 1202 stock tax incentive.
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
