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Tax Professionals – Question Of The Week For You!

Tax Advisor’s – What Are Your Thoughts On This Question Of The Week?

My client has an 1120-F entity and wishes to convert it to a C-Corp or S-Corp. Is there a way to do this without any tax implications? He is a US citizen and the corp has two buildings that generate rental income.

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One thought on “Tax Professionals – Question Of The Week For You!

  1. Avatar Yosef Klein says:

    I would look at the F reorganization rules under IRC Section 368(a)(1)(F) and Regs. Sec. 1.368-2(m)(1). The fact pattern seems to be eligible for for non-recognition under this rule.

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