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Internal Revenue Code (IRC) Conversion

Holland & Knight LLP

A Look at Transfers of Section 1202 Qualified Small Business Stock

Holland & Knight LLP on

Section 1202 of the Internal Revenue Code provides that noncorporate taxpayers may exclude certain gains on the disposition of Qualified Small Business Stock (QSBS) held longer than the minimum required holding period. One...more

Hinckley Allen

Converting an LLC to an S Corporation: A Mistake Waiting to Happen

Hinckley Allen on

Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more

Cadwalader, Wickersham & Taft LLP

Entity Conversion Under State Law Is Not a Modification of Debt

After almost 20 years, the IRS has again ruled that the conversion under state law of a limited liability company (LLC) disregarded for tax purposes to a corporation did not result in a “significant modification” of the...more

Wilson Sonsini Goodrich & Rosati

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

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