JD Supra

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part III – Code Section 1361(b)(1)(C)

This third installment of my multi-part series on Subchapter S is focused on a single Code Section, namely IRC Section 1361(b)(1)(C) and the ineligibility of nonresident aliens as shareholders of ...
JD Supra

A Journey Through Subchapter S / A Review of The Not So Obvious & The ManyTraps That Exist For The Unwary: Part I – The Built-In-Gains Tax

Fast forward 24 years when tax advisers saw the enactment of the Subchapter Revision Act of 1982 (the “82 Act”). The 82 Act removed most of these flaws or reduced the negative impact of the existing ...