Christine Walizer, Author at The S Corporation Association

Pass Through Loopholes?

The pass through mantra, supported by more than 100 national business trade groups, is simple – tax business income once, tax it when its earned, tax it at the same reasonable top rate, and then leave it alone!

Do you want to stop inversions and keep American corporations here at home? Adopt the mantra. Do you want to make sure Main Street continues to be a source of job creation and economic stability? Adopt the mantra.

We’ve been on this message for five years, and sometimes you get the sense it’s starting to sink in. For example, the Brady blueprint …

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admin2019-02-01T19:56:24+00:00August 15, 2016|

Treasury Hits Family Businesses!

The verdict is in, and Treasury’s proposed rules on estate tax valuations of family-owned businesses are broad – very broad indeed. They are, simply put, a direct assault on America’s family-owned businesses.

Here’s the take of WealthManagement.Com:

Although the details are significant, the bottom line is that the proposed regulations would appear to eliminate almost all minority (lack of control) discounts for closely held entity interests, including active businesses owned by a family. To accomplish that, restrictions under the governing documents and even those under state law would be disregarded for valuation purposes.

And Steve Leimberg’s Estate Planning Email Newsletter:

In short, …

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admin2019-02-01T19:56:24+00:00August 9, 2016|

Treasury’s Proposed Minority Discount Rules Finally Released

The regulatory assault continues – this time in the form of newly proposed rules out of Treasury to increase valuations – and taxes – on family businesses when they are transferred as part of an estate.

These are the long-awaited rules Treasury officials foreshadowed as far back as the Spring of 2015, and they appear to be consistent with the Obama budget proposal offered back in 2012 that was estimated to raise $18 billion over ten years!

While the rules were just released yesterday, their impact on family partnerships and estate plans is already the hot topic of debate with …

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admin2019-02-01T19:56:24+00:00August 3, 2016|

S-Corp Mod Bills Introduced!

Good news on a hot day in July! The 2016 version of the “S Corporation Modernization Act” has been introduced the House and the Senate. Led by Senators Thune (R-SD) and Cardin (D-MD) and Representatives Reichert (R-WA) and Kind (D-WI), the bill includes a half-dozen provisions designed to improve the rules that govern S corporations.

You can see the entire bill here
You can see the section-by-section analysis here
You can see the S-Corp press release here

Yesterday’s introduction of companion bills is the first time in a while that the S corporation community has had this important …

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admin2019-02-01T19:56:24+00:00July 14, 2016|

S-Corp Submits 385 Comments

The debate over Section 385 continues. The comment period ends today, and we sent in our comment letter along with the rest of the business community.

As we noted in our submission, the 385 regulations were advertised as a response to base erosion practices, but the rule itself is not limited to international transactions. Nor is it limited to businesses of a certain size. Instead, it targets the related party debt of domestic businesses of all sizes. As our comments state:

Since their release, the broader business community has raised numerous concerns regarding scope of the Proposed Regulations, including the statutory authority …

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admin2019-02-01T19:56:24+00:00July 7, 2016|