108 resultados — página 2 de 6

• 26 CFR §301.9100-21References to other temporary elections under various tax acts.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  Election to treat qualified subchapter S trust as a trust described in section 1361(c)(2)(A)(i), under the Subchapter S Revision Act of 1982. 18.1362-1 Election

• 26 CFR §1.1377-1Pro rata share.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  eligible shareholder of the S corporation converts from a trust described in section 1361(c)(2)(A)(i), (ii), (iii), or (v) for the first part of the year ... trust described in a different subpart of section 1361(c)(2)(A)(i), (ii), or (v) for the remainder of the year, the trust's share of the S corporation

• 26 CFR §301.6231(a)(2)-1Persons whose tax liability is determined indirectly by partnership items.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  Shareholder of C corporation. A shareholder of a C corporation (as defined in section 1361(a)(2)) is not a partner in a partnership merely because the C corporation

• 26 USC §1368Distributions
  Federal (EE. UU.)Sección de códigoVigencia: 2024-12-31

  corporation with respect to any restricted bank director stock (as defined in section 1361(f)), the amount of such distribution— (1) shall be includible in gross income of the director

• 26 CFR §301.6221(b)-1Election out for certain partnerships with 100 or fewer partners.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  partnership with a partner that is an S corporation (as defined in section 1361(a)(1)) must take into account each statement required to be furnished by the S corporation ... means a partner that is an individual, a C corporation (as defined by section 1361(a)(2)), an eligible foreign entity described in paragraph (b)(3)(iii) of this section

• 26 CFR §1.444-4Tiered structure.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  include a trust that is treated as an electing small business trust under section 1361(e). An S corporation with an electing small business trust as a shareholder may make

• 26 CFR §301.6037-2Required use of electronic form for returns of electing small business corporation.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  term electing small business corporation means an S corporation as defined in section 1361(a)(1). (5) Calculating the number of returns. For purposes of this section, a corporation

• 26 CFR §1.1374-8Section 1374(d)(8) transactions.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  acquired in the same transaction. If an S corporation makes QSub elections under section 1361(b)(3) for a tiered group of subsidiaries effective on the same

• 26 CFR §1.172-4Net operating loss carrybacks and net operating loss carryovers.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  rule applicable to corporations which were electing small business corporations under Subchapter S (section 1361 and following), chapter 1 of the Code, during one or more of the taxable years

• 26 CFR §1.6418-1Transfer of eligible credits.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  term transferee S corporation means an S corporation within the meaning of section 1361(a) that is a transferee taxpayer. (m) Transferee taxpayer. The term transferee taxpayer means any taxpayer ... term transferor S corporation means an S corporation within the meaning of section 1361(a) that is an eligible taxpayer that makes a transfer election. (p) Transferred specified credit portion

• 26 CFR §1.250(a)-1Deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  trust (as defined in section 856), or an S corporation (as defined in section 1361). (2) Foreign-derived intangible income (FDII). The term foreign-derived intangible income or FDII

• 26 CFR §1.194-2Amount of deduction allowable.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  this section shall apply in the case of S corporations (as defined in section 1361(a)) and their shareholders. (7) Estates. Estates may elect to amortize in each taxable year

• 26 CFR §1.7872-5TExempted loans (temporary).
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  borrower is a shareholder that is not a C corporation as defined in section 1361(a)(2)) if the lender is a foreign person and the borrower

• 26 CFR §1.6045B-1Returns relating to actions affecting basis of securities.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  that asserts that the holder is not an S corporation as defined in section 1361(a). (D) The issuer receives a withholding certificate described ... payee.” (c) Special rule for S corporations. An S corporation (as defined in section 1361(a)) is deemed to satisfy the requirements of paragraphs (a) and (b) of this section

• 26 CFR §1.1362-3Treatment of S termination year.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  entire shareholder interest to T, a trust not permitted as a shareholder under section 1361(c)(2). S ceases to be a small business corporation on March

• 26 CFR §1.1248(f)-1Certain nonrecognition distributions.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  defined in section 856(a)), or an S corporation (as defined in section 1361(a)) cannot be a section 1248 shareholder. (13) Timely filed return is a U.S. income

• 26 CFR §1.641(c)-1Electing small business trust.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  general. An electing small business trust (ESBT) within the meaning of section 1361(e) is treated as two separate trusts for purposes of chapter 1 of the Internal Revenue Code ... ESBT for part of the year and an eligible shareholder under section 1361(a)(2)(A)(i) through (iv) for the rest of the year. (ii) Special rule for charitable

• 26 USC §280GGolden parachute payments
  Federal (EE. UU.)Sección de códigoVigencia: 2024-12-31

  paragraph (2)(A)(i)) was a small business corporation (as defined in section 1361(b) but without regard to paragraph (1)(C) thereof), and (ii) any payment to a disqualified

• 26 CFR §1.409(p)-1Prohibited allocation of securities in an S corporation.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  this section. (vii) S corporation means S corporation within the meaning of section 1361. (viii) Synthetic equity has the meaning set forth in paragraph (f) of this section. (b) Prohibited ... following example: Example. (i) Facts. Corporation M, an S corporation under section 1361, establishes Plan P as an ESOP in 2006, with a calendar plan year. Plan

• 26 CFR §1.48D-2Definitions.
  Federal (EE. UU.)ReglamentoVigencia: 2026-07-17

  service during the taxable year by an S corporation (as defined in section 1361(a) of the Code) must be apportioned pro rata among the S corporation's shareholders