Discussion:LLP converted to PLLC - taxed as a s-corp.
From TaxAlmanac, A Free Online Resource for Tax Professionals
Note: You are using this website at your own risk, subject to our Disclaimer and Website Use and Contribution Terms.
From TaxAlmanac
(Difference between revisions)
Current revision
Discussion Forum Index --> Basic Tax Questions --> LLP converted to PLLC - taxed as a s-corp.
Discussion Forum Index --> Tax Questions --> LLP converted to PLLC - taxed as a s-corp.
| 5 August 2009 | |
I have a client (law firm) which was a LLP and formed a PLLC taxed as a S-corp for 2008. The client has filed to appropriate forms, 2553 and the Articles of Organization with the Sec. Of State. My question is, what are the tax implications of this. I know that 721 applies when a general partnership converts to a LLC taxed as a partnership, but what about when the LLC is taxed as a s-corp? Does 351 apply? Since no stock was issued, just ownership interest, how can 351 apply. I have researched this topic and have found limited information - am I missing something? My thinking is that the assets liabilities come over at historical cost, but what about the capital accounts? Are capital accounts no longer used and paid in capital used with no common stock? Also, two of the partners of the LLP had negative capital accounts before conversion and one had positive capital - does this complicate things? See below for simple example. Any help would be greatly appreciated.
Capital accts
| |
