Special Rules for Deducting Unused S Corporation Losses and Claiming Nontaxable Distributions
Measuring PTTP Under Treas. Reg. 1.1377-2, Increasing Stock Basis During PTTP, Treatment of Post-Termination Dividends
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers and compliance professionals with a thorough exploration of the risks and opportunities of deducting unused S corporation accrued losses in the "post-termination transition period" (whether due to revocation of S election, winding down of the business, or a disqualifying event). The panelist will detail how the 2017 tax reform law changed the treatment of carryforward S corp disallowed loss amounts, strategies to maximize the tax advantages of making an S to C corp election and the Proposed Regulations issued November 2019 covering post-termination transition period distributions by eligible terminated S Corporations (ETSCs).
Outline
- Prior treatment of unused S corp losses carried forward at the termination of S election or company operations
- Relief guidance
- Eligible termination events
- Measuring PTTP
- Treatment of losses suspended due to Section 465 at-risk limitations
- Increasing basis during PTTP
- Proposed Regulations on distributions made after S corp termination
Benefits
The panelist will discuss these and other important topics:
- The standards and events listed in Treas. Reg. 1.1377-2 for measuring an S corporation's PTTP
- Fixing carryforward losses potentially eligible to be freed-up at the beginning date of the PTTP
- How S corp shareholders may increase their stock basis during the PTTP to free-up previously disallowed losses
- Tax treatment of distributions made during PTTP
Faculty
Professor Robert W. Jamison, CPA
Professor Emeritus of Accounting
Indiana University
Mr. Jamison is Professor Emeritus of Accounting at Indiana University, Purdue University, Indianapolis (IUPUI). His... | Read More
Mr. Jamison is Professor Emeritus of Accounting at Indiana University, Purdue University, Indianapolis (IUPUI). His principal area of specialization is S Corporations. He is the sole author of S Corporation Taxation, and co-author of Multistate Tax Guide to Pass-Through Entities, both of which are published annually by CCH, a Wolters Kluwer business. He is a regular contributor to Land Grant University Tax Education Foundation, Inc. National Income Tax Workbook and has contributed to Federal Tax Workshop. He presents advanced and update S Corporation seminars for various states' CPA societies and to other professional organizations. He is a member of the AICPA S Corporation Technical Resource Panel. He consults on S corporation and other business entity problems and has secured letter rulings from the IRS.
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