Current developments in S corporations

[...]class of stock created by partnership operating agreement: [...]if all parties contributed capital to the entity pro rata in accordance with their percentage interest in the LLC and all allocations of income were made pro rata to the members, then presumably the dollar figures that the members...

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Bibliographic Details
Published in:The Tax Adviser 2021-06, Vol.52 (6), p.374-385
Main Authors: Hill, Kristin, Jamison, Robert W., Jr, Keller, Robert S, Orbach, Kenneth N, Scott, Alexander, Walsh, Kevin J, Wilson, Sheryll
Format: Magazinearticle
Language:English
Subjects:
Agreements
Annual reports
Compensation plans
Corporations
Elections
Incorporation
Investments
Limited liability companies
Losses
Nonprofit organizations
Provisions
Put & call options
S corporations
Shareholder voting
State court decisions
State laws
Stockholders
Tax courts
Taxation
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Summary:[...]class of stock created by partnership operating agreement: [...]if all parties contributed capital to the entity pro rata in accordance with their percentage interest in the LLC and all allocations of income were made pro rata to the members, then presumably the dollar figures that the members ultimately were entitled to through ordinary or liquidating distributions would be identical. [...]class of stock not created by mixed-use opportunity fund: [...]a new tax adviser was obtained in year 3 who informed Z s member that the restructuring had not been done. [...]a restructuring occurred in year 4 whereby Z acquired all the stock of W and X, with the intention to treat them as qualified Subchapter S subsidiaries (QŞubs).The stock of У was transferred to eligible S shareholders.
ISSN:0039-9957