Discussion:C Corp converted to S Corp then dissolved

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Discussion Forum Index --> Advanced Tax Questions --> C Corp converted to S Corp then dissolved
Discussion Forum Index --> Tax Questions --> C Corp converted to S Corp then dissolved

Eaglecpa (talk|edits) said:

14 May 2008
I have a new client that is dissolving their S Corp. Details: this was a C Corp in 06 w/ NOL and PIC from sole shareholder. S election effective for 07 and then the company dissolved at the end of the year. My question is as follows: does the Add'l PIC from the C Corp transfer to stock basis in the S Corp - such that when we dissolve the S Corp we can take a capital loss for this basis?

JR1 (talk|edits) said:

May 14, 2008
Basis transfers. The NOL is *poof*.

Marcilio (talk|edits) said:

15 May 2008
Hope they has ยง1244 stock.

Eaglecpa (talk|edits) said:

15 May 2008
Thanks for your replies. Unfortunately the value of the stock purchase was very low and I don't think that PIC qualifies as section 1244. Correct me if I'm wrong - thx

Marcilio (talk|edits) said:

17 May 2008
The original stock had to designated as 1244 stock. You have to check the corporate record book. PIC from initial capitalization can qualify.

JR1 (talk|edits) said:

May 19, 2008
1244 has been automatic since the mid 70's, M, if it meets the qualifications.

Marcilio (talk|edits) said:

19 May 2008
I didn't know that, thanks.

Eaglecpa (talk|edits) said:

23 May 2008
The stock & PIC qualifies but they do not have anything in writing that designates it as 1244. I suppose this could be added after-the-fact?

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