Article Abstract:
Liberalized provisions in the Small Business Job Protection Act of 1996 and resultant IRS regulations under IRC section 1361 have provided new business and tax planning opportunities for Subchapter S corporations. S corporations may own qualified subsidiary corporations and may elect to disregard those subsidiaries and treat them as pass-through entities for tax purposes. More Subchapter C corporations and businesses in other forms may elect S corporation status to take advantage of these tax benefits.
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Article Abstract:
Tax consequences are substantially different in accordance with the various forms of business entities which parent corporations may choose for new or reorganized subsidiaries. IRS check-the-box regulations have allowed great flexibility in designing business structures. The advisability of use of partnerships, limited liability companies, or other pass-through entities depends upon nontax reasons and tax reasons which vary situationally for different taxpayers.
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Article Abstract:
The author presents an explanation of the concept of and procedures regarding transfer pricing. IRC section 482 mandates arms-length pricing determinations for transactions carried on between related business enterprises. This mandate is controlled by a great quantity of IRS regulatory substantive and procedural rules as well as by case law.
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