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Qsub

Revocation of parent’s S status means former QSub must separately account for income, etc.

Revocation of parent’s S status means former QSub must separately account for income, etc.

Chief Counsel Advice 201433014 In Chief Counsel Advice (CCA), IRS has determined that an S corporation that became a C corporation during the tax year cannot prorate, between the S corporation and C corporation, any items that arose with respect to its former QSub after the date on which its S status terminated. IRS also […]

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Third Circuit affirms: Qsub election doesn’t increase shareholder’s basis in S corporation

Third Circuit affirms: Qsub election doesn’t increase shareholder’s basis in S corporation

In R. Ball, etc.,  et al., vs. Commissioner (Court of Appeal 3rd Cir.,2/12/2013) 113 AFTR 2d ¶ 2014-494, the Third Circuit, affirming a Tax Court opinion, has ruled that an election by an S corporation to treat its subsidiary as a qualified Subchapter S subsidiary (QSub) did not increase the basis of the S corporation’s […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney