Leadership

Essay specific features

 

Issue:

Social Issues

 

Written by:

Gary H

 

Date added:

September 18, 2015

 

Level:

University

 

Grade:

A

 

No of pages / words:

6 / 1472

 

Was viewed:

958 times

 

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Essay content:

Passive Income 2. Built in Gains Passive Income - S Corp that has subchapter C earnings and profit - S Corp with passive income o Gross receipts exceed 25 percent of passive activity (pay income tax) o Gross receipts exceeds 25 percent for 3 years (S Corp termination) Built in Gains - Conversion from C Corp to an S Corp - Any appreciated assets as date of conversion are called Net Built in Gain o Within 10 years if you sell assets you are subject to tax Subsection 1363(b)- S Corporations taxable income is calculated in the same manner as an individual Exceptions to 1363(b): - Personal Exemptions under Section 152 are not deductible - Charitable Contributions under Section 170 are not deductible - Any additional itemized deductions (medical) Taxation at Shareholder Level Subsection 1366(a)- all items of income, deduction, loss, and credit recognition by S Corp are passed through to the shareholder Knott v...
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Commissioner TC Memo 1991-352 - Shareholders are taxed on their allowable share of income even if not distributed Subsection 1366(b)- Character of any item included in a shareholder pro-rata shares shall be determined as if it we realized directly from the source and incurred in the same manner as a corporation Exceptions to 1366: - Regulation 1...
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