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Tax Court In Brief: A Single Shareholder Corporation | TaxConnections
A single shareholder (“Shareholder”) owned 100% of the stock and served as the sole director for the petitioner. For a period of 5 years, petitioner paid the Shareholder wages until a change in compensation structure. Moving forward, petitioner leased the Shareholder’s services through offshore employee leasing transactions (OEL transactions). During this period, petitioner furnished Shareholder with space to perform personnel services, loaned Shareholder an automobile for business use, and provided health insurance benefits, at petitioner’s cost.