Liquidating an s corp dating service toronto teen quiz

12-Jun-2015 00:26

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Under this technique, the deemed distribution of a one-day note from the S corporation to its shareholders mirrors the favorable tax treatment of an S corporation's selling its assets in exchange for an installment note and remaining in existence, distributing the payments on the note to its shareholders. 453, 453B, and 338(h)(10) were issued, practitioners hoped that the same treatment would result whether or not the S corporation remained in existence.

However, the regulations provide otherwise where the S corporation receives and distributes an installment note plus other property or cash as part of the sale of its assets.

Assume the existence of an S corporation with assets having a value of ,000 and an adjusted basis of 0.

This is the case whether that sale is only deemed to have occurred under Sec.

338(h)(10) or was an actual sale of the S corporation's assets.

Wechter August 23, 2012 AICPA Corporate Taxation Insider The "one-day note" is a popular planning technique for a Sec.338(h)(10) installment sale of the stock of an S corporation where the S corporation is deemed to have liquidated.