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.
Every Friday, TaxConnections addresses a question submitted to our Ask Tax Questions platform. We ask our members to offer their thoughts on the question of the week. We realize you may need more information which you can request in the comments section below or on the TaxConnections website directly with our visitor.
Please comment below or log in to TaxConnections to answer the Question Of The Week. If you are not a member at TaxConnections sign up here
Kat Jennings, Founder of ET Search LLC offering retained tax search services and TaxConnections Inc., the leading tax professional branding platform. Through ET Search LLC, we provide: 1) Internationally recognized, retained executive tax search services for multinational corporations, public accounting firms, and law firms; and through TaxConnections: 2) Provide brand building services to expand the reach of tax professionals and their firms.
The tax candidates we introduce to clients are hidden and will never submit a resume through a resume portal tracking their activity. This leaves an underground population of tax candidates inaccessible to most companies who seek technically sophisticated tax executives for their open tax roles.
As a globally recognized consultant to multinational organizations, accounting firms, and law firms searching for tax expertise, Kat has been retained by public accounting firms, law firms, and corporations worldwide including Apple Computer, AC Neilson, Accenture, Agilent Technologies, Allergan, Alza, American Express, American Media, Aon, Baker & McKenzie, Barclays Bank, Bechtel, Cargill, Carl Zieuss Vision, Century Aluminum, Chevron, Clorox, Citigroup, Commercials Metals, Constellation Energy, Countrywide, Del Monte, Deloitte Touche, DFS, DLA Piper, E&J Gallo Winery, Electronic Arts, Ernst &Young, Fox Entertainment, Fremont Investments, General Electric, General Motors, Herbalife, Hewlett Packard, Hyatt, Intel, Jones Lang LaSalle, Kimco Realty, KLA Tencor, Koch Industries, KPMG, Levi Strauss, Liberty Mutual, LKQ, Loews, Logitech, Lucas Film, Maersk, McKesson, Nalco, Newell Rubbermaid, Nissan, Oracle, Orbitax, Pacific Gas & Electric, PwC, QAD, SAIC, SanDisk, Sanmina, Sempra Energy, SONY, Synopsys, Ticketmaster, Trimble Navigation, Toyota, Univar, Wells Fargo, Vertex, Yahoo, Xilinx, and many more not listed here.
Learn how we operate at https://etsearch.com/retained-tax-executive-search/
Contact Kat at 858,999.0053 Office/858.232.4415 Cell or kat@etsearch.com to request a private consultation about a search.
Join us as a TaxConnections Member to expand your brand. https://www.taxconnections.com/membership/sign-up
1 comment on “Tax Professionals – Question Of The Week For You!”
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.
Comments are closed.