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).