Thought-provokinganalysis and opinion on federal tax issues

Category Archives: Corporations and Shareholders

New S Corporation Case And The Check-The-Box Regulatons

September 19, 2020

by Monte A. Jackel

This case came out today. https://www.ustaxcourt.gov/USTCInOp2/OpinionViewer.aspx?ID=12322.  1. It deals with whether a controlling person of a Kentucky not for profit corporation was an S corporation shareholder.  2. I do not disagree with the holding of the court, which seems very apparent; beneficial ownership, a proprietary interest, is necessary to be a shareholder. 3. However, the mode […]

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