4 companies are, through ownership, in the same controlled group.
One company insists that it should not be considered a member of the controlled group because it is "just a sub-s corporation" and the company has never been used to control income or accumulate profits.
I have never before heard this type of argument. Is there merit to this argument for not being considered part of a controlled group of companies?
Any tax-gurus available to weigh in?
Thank you, thank you
Full Version: A sub-S corporation as part of the Controlled Group
S-corps can be members of a controlled group just like any other corps or partnerships or sole-proprietorships--at least for pension purposes (under IRC Sections 414(b) & © & 1563). I don't know the rules about filing consolidated returns, however.
What? Doesn't an S corporation mean I have a "Get out of RULES Free" card?
I've heard the claim in the context of contol and affiliated service groups time and again from one-trick ponies all of whose clients are in S corporations (or, alternatively, all in LLCs).
I've heard the claim in the context of contol and affiliated service groups time and again from one-trick ponies all of whose clients are in S corporations (or, alternatively, all in LLCs).
QUOTE (Iwonder @ Sep 18 2008, 05:39 PM) 
4 companies are, through ownership, in the same controlled group.
One company insists that it should not be considered a member of the controlled group because it is "just a sub-s corporation" and the company has never been used to control income or accumulate profits.
I have never before heard this type of argument. Is there merit to this argument for not being considered part of a controlled group of companies?
Any tax-gurus available to weigh in?
Thank you, thank you
One company insists that it should not be considered a member of the controlled group because it is "just a sub-s corporation" and the company has never been used to control income or accumulate profits.
I have never before heard this type of argument. Is there merit to this argument for not being considered part of a controlled group of companies?
Any tax-gurus available to weigh in?
Thank you, thank you
IRC 1371(a) "Except as otherwise provided in this title ...Subchapter C shall apply to a subchapter S corporaton and its shareholders." Title refers to the IRC.
All the information provided is very helpful and just what is needed to move on. Thank you everyone.
Tax gurus, you rock!
Tax gurus, you rock!
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