Acquiring a “C” with an “S”? Consider Making a Qsub Election

Have an “S” Corporation?  Want to acquire a corporation and treat it as a subsidiary?  Want to avoid double taxation on the acquired corporation’s income?  Consider making a Qsub election. An “S” corporation can acquire and own the stock of a “C” corporation.  But having an “S” corporation own a “C” corporation may not make…

Profits Interest vs Capital Interest – What’s the Difference?

When an ownership interest in a partnership (or LLC taxed as a partnership) is transferred to a member in exchange for services, the tax consequences of such transfer are governed by partnership tax law.  Ownership interests in partnerships can be profits interest, capital interests or both.  Partnership tax law is quite complex, and there is…