An electing large LLC is one with at least 100 members in any preceding tax year that elects to be subject to the electing large partnership rules.
If a large LLC elects to pay the imputed tax, the LLC, not the members, is subject to the interest thereon, as well as any penalties.
Of course, if an employee
elects to pay for disability coverage on an after-tax basis, the coverage's cost will be subject to employee and employer payroll taxes--in addition to employee income tax.
Thus, the regulations do not require a current-year transfer to the trust for which the termination statement is being filed, nor do they require a gift tax return to otherwise be filed in the year a taxpayer
elects to terminate a previous election out.
26.2632-1, the taxpayer
elects to allocate the smallest amount of the taxpayer's GST exemption necessary to provide a zero inclusion ratio (as defined in Set.
If the corporation
elects to use the specific-accounting method, affected shareholders must consent to the election.
2632(c), unless the individual
elects to opt out of the automatic allocation under Secs.
453(a) requires income from an installment sale to be reported under the installment method unless the taxpayer
elects to have such method not apply to a particular disposition.
In addition, if the spouse who files as married filing separately
elects to itemize deductions, may the spouse who files as head of household claim the standard deduction for head of household status?
If the taxpayer
elects to include the amortization of the discount as current-year income, Sec.
This option potentially results in the constructive receipt of income in 1998, even if the taxpayer
elects to receive the payments in 1999.
If the corporation
elects to use the specific accounting method, all the shareholders affected by the stock disposition must consent.
Corporation
elects to file as 1120 Corporation in [tax year]." There was no statement as to the fact that more than 50% of the shares so voted.
97-002, all LLCs (including SMLLCs) organized after 1996 will be classified as partnerships for Alabama tax purposes, unless the LLC
elects to be classified as a corporation under the FCBRs.
Under the proposed rules, if a resident alien shareholder of an S corporation
elects to be taxed as a nonresident alien under a treaty "tiebreaker" provision, the corporation's status as an S corporation will terminate, unless --the nonresident alien shareholder agees to be taxed on the income earned through the S corporation, and--the S corporation agrees to withhold on amounts attributable to the nonresident alien shareholder.
