Does anyone have a good source for information on the steps/implications of converting from a Subchapter S corp to a C corp?

I am exploring options for avoiding the impact of IRC sec. 409(p) on an S corp ESOP.

I haven't worked through one of those, but I've been told that they can be some very nasty tax consequences imposed upon such a conversion at least in some circumstances. My recollection is that these taxes have nothing to do with the fact that the company has an ESOP.

My recommendation is that you retain competent tax counsel to advise you on this matter.