S Corporations: Conversions

Description

Electing S corporations may find it desirable or necessary to terminate this election and convert to a C corporation. Terminating S corporations can be desirable with important current and future tax considerations. We'll consider situations when such conversions are desirable. Identifying and discussing tax planning opportunities and complications at conversion. Also, considers recent and pending legislation.

Highlights

• Reasons to terminate an S corporation election
• Involuntary terminations
• Voluntary revocations the process and the consequences
• Tax planning opportunities related to the termination of S corporation status
• Complications arising from a mid-year termination
• Limitations on re-electing S corporation status
• Recent or proposed legislation affecting the decision to terminate the S corporation election
• Making the S corporation election how and why
• Built-in gain planning.

Objectives

• Gain a working knowledge of all the foreign information returns.
• Identify key defenses to IRS criminal and civil penalties for erroneous foreign returns or non-filed foreign returns.
• Recognize the significance of the IRS voluntary disclosure policy as it relates to offshore transactions and accounts.

Designed For

CPAs and attorneys.