Re: [taxchat] (unknown)

Qualified Subchapter S Corporation Subsidiary (QSSS): A Subchapter S corporation can elect to treat a wholly owned subsidiary as part of the Subchapter S corporation for tax purposes. Therefore, the subsidiary is disregarded for tax purposes. The subsidiary does not need to be a Subchapter S corporation, but it must be a corporation that would qualify as a Subchapter S corporation if its stock was held by the shareholders of the parent Subchapter S corporation.

Qualification requirements for QSSS status:

1) The parent Subchapter S corporation must own 100% of the subsidiary.
2) The parent Subchapter S corporation must make an election to treat the subsidiary as a QSSS.
3) The subsidiary must be a domestic corporation.

Tax Effects of Election:

—Existing Corporation: If an election is made to treat an existing corporation as a QSSS, the transaction is treated as a liquidation of the subsidiary under IRC §332 and §337. 

—New Corporation:

If a QSSS election is in effect when the subsidiary is formed, liquidation is not considered to have occurred. The QSSS is disregarded for tax purposes.

Making Election: See IRS Notice 97-4 and Proposed Regulations Caution: Not all states recognize a QSSS election. Some states treat the QSSS as a separate entity for state tax purposes.

QSST Qualified Subchapter S Trust

 http://www.nysscpa.org/cpajournal/old/08135898.htm

What sort of help do you need?

 

KC Jenkins

On Thu, Nov 20, 2008 at 9:29 AM, <mjacobs1@bellsouth.net> wrote:

has anyone in the group have experince with "qsss" and "qsst" need help !!!!!!

__._,_.___

IRS Circular 230 Disclosure: Unless expressly stated otherwise in this transmission, any tax advice contained herein, forwarded with or attached to this message was not and is not intended to be used, nor may it be relied upon or used, by any taxpayer for the purpose of (1) the avoidance of any tax-related penalties under the Internal Revenue Code or applicable state or local tax law provisions, or (2) promoting, marketing or recommending to another party any tax transaction or tax-related matters that may be addressed herein.

Your email settings: Individual Email|Traditional
Change settings via the Web (Yahoo! ID required)
Change settings via email: Switch delivery to Daily Digest | Switch to Fully Featured
Visit Your Group | Yahoo! Groups Terms of Use | Unsubscribe

__,_._,___