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Choosing the Best Legal EntityTHE TEN FEDERAL INCOME TAX ISSUES MOST LIKELY TO BE DECISIVE IN TAX CHOICE OF ENTITY ANALYSIS 1) Subchapter S eligibility and election requirements. Do the Subchapter S eligibility and election rules cause that subchapter to be disadvantageous to an entity for federal income tax purposes as compared with sole proprietorship taxation and Subchapter K? 2) Contributions of appreciated property. Which federal income tax regimen provides the entity in question and its owners with the most favorable federal income tax treatment with respect to contributions of appreciated property to entities in connection with their formations? 3) Post-formation contributions of property. Which federal income tax regimen provides the entity in question and its owners with the most favorable federal income tax treatment with respect to post-formation contributions of appreciated property to entities? 4) Special allocations and distributions. Which federal income tax regimen provides entities and their owners with the most favorable federal income tax treatment with respect to special allocations and distributions by entities to their owners? 5) Distributions of property. Which federal income tax regimen provides entities and their owners with the most favorable federal income tax treatment with respect to distributions of property by entities to their owners? 6) Redemptions. Which federal income tax regimen provides entities and their owners with the most favorable federal income tax treatment with respect to redemptions of ownership interests? 7) Sellers of ownership interests. Which federal income tax regimen provides the best federal income tax treatment to sellers of ownership interests in entities? 8) Purchasers of ownership interests. Which federal income tax regimen provides the best federal income tax treatment to buyers of ownership interests in entities? 9) Inclusion of entity debt in owner basis. Which federal income tax regimen provides the best federal income tax treatment to owners with respect to the inclusion of entity debt in owners' bases in their ownership interests? 10) Grants of restricted ownership interests and options to purchase ownership interests. Which federal income tax regimen provides the best federal income tax treatment to entities and their owners with respect to the granting of restricted ownership interests and of options to purchase ownership interests? Ronald J. Cappuccio, J.D., LL.M.(Tax), a LLC Lawyer and Business and Tax Attorney. We can help you start a Limited Liability Company ( LLC ) which can be the best form of business organization, as well as establish Corporations, S Corporations, Partnerships, Limited Partnerships and Non-Profit organizations. We also can represent you in Buying and Selling a business. helping emphasizing Personal and Business IRS Tax Negotiation, Offers In Compromise, and Installment Agreements. Zealous representation in Tax Audits, Delinquent Tax, and Tax Collections Issues. Experience fighting Employee and Independent Contractor issues, Payroll Taxes, Tax Liens,and Tax and Labor Audits. Successfully handle Wage Levy Release, Bank Levies and Seizures. NJ Tax Court, US Tax and US Court of Federal Claims representation. We also can represent you in Buying and Selling a business. |
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