Our lock mount introduce your speaker for today is Vicky mu lock Vicky is an enrolled agent and certified financial planner CFP and owner of American financial and tax a tax preparation planning and representation firm which has founded in Tustin California in 1985 when Vicky became both a resident and it was dishonor Vicky is a well-known presenter on federal and California tax law with all the answers as continuing education events hosted by various professional organizations she's also an author of numerous articles that have been appeared in very instructional journals in addition to her private practice Vicky serves on two of the three California state tax agency advisory boards the California Franchise Tax Board advisory board in 2023 and the Employment Development departments small business employers Advisory Committee since 1997 she has been honored with numerous awards for his English service in legislation advocacy and educational goals from the enrolled agent Association and a EA and cs/ei she resides with her husband George in Boston Vicky's work at the program we are now ready to begin thank you very much Michael and welcome to all of our attendees today to this presentation on kind of a unusual topic it's a little bit of a complex topic to I will just warn you at the outset here and if it does helps anyone complex for me as well and I think one of the reason that these elections are a bit complex is that these elections actually or a type of almost tax fiction where we report on our tax returns under an election something that didn't really happen but that we can report it as if it happened and we're going to look at actually three different elections today there are two 338 elections the regular and...
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Mechanics of 336 e election Form: What You Should Know
B) Availability of election. A section 336(e) election is available if seller and target enter into a written agreement. The section 336(e) election is treated as if written on the day that the S corporation target makes its first payment before any disposition, but must be filed with the seller within thirty days after making the first such payment. Definition of S corporation or S Corps. For purposes of this section, a “S corporation” is a corporation for which all the shareholders (or, for an S corp. that is a partnership, all the partners) are shareholders of another corporation, and either: (1) Each of the owners is a share owner of a partnership in which the S Corp. has a subchapter X (or CZ) tax treatment, or is an S corp. as defined by 26 U.S.C. § 1350(e). (2) (i) The S corporation is any domestic corporation with one or more Subchapter X (or CZ) tax treatment subsidiaries (including partners in such a partnership). (ii) The S Corp. has one or more qualifying S corporations or subchapter S (or CZ) tax treatment subsidiaries, or a combination of qualifying S corporations and subchapter S (or CZ) tax treatment subsidiaries, for the same taxable year; and For the purpose of this section, the qualifying S corporations are qualifying S corporations. (3) or (iii) The S corp. is a partnership, and: (A) Each partnership member and partner is a shareholder of another partnership with which the S Corp. has a tax treatment subchapter S (or CZ) tax treatment. For example, an S corporation is a qualifying S corporation if its shareholders are all partners of a partnership with which the S Corp. has a subchapter S (or CZ) tax treatment subsidiary. Similarly, the S Corp. is an S corp. with respect to a partner if there is a partnership relationship between the S Corp. shareholders (whether in the S Corp. as a general partner or as a general partner in another partnership) and either (A) A subpart F tax treatment subsidiary from which the S Corp.
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