S Election Did Not Trigger Recapture of Dual Consolidated Losses Where Closing Agreement Was Signed
Date
2005
Authors
Harvey, Carol Kulish
Outenreath, Alyson
Tod, Jim
Journal Title
Journal ISSN
Volume Title
Publisher
Abstract
A discussion of an IRS ruling stating that under certain circumstances, an S corporation election would not trigger a dual consolidated losses recapture if a closing agreement was entered into by the parent company, its shareholders, and the IRS.
Description
Keywords
S corporation election, dual consolidated losses, closing agreement, tax law, S election, loss recapture, IRS
Citation
Carol Kulish Harvey, Alyson Outenreath, & Jim Tod, S Election Did Not Trigger Recapture of Dual Consolidated Losses Where Closing Agreement Was Signed, 7 No. 4 Bus. Entities 57 (2005).