SCorp terminates election

[Rae]

TTB pg 18-14

Check the Box Rules:
If an entity elects to be taxed as a corporation under the check-the-box rules, the entity is subject to corporate liquidation rules if it ever wants to uncheck that box and go back to being treated as a partnership or sole proprietorship. See Corporate Liquidations, page 18-19.

[BOB W]

Check the Box Rules:
If an entity elects to be taxed as a corporation under the check-the-box rules, the entity is subject to corporate liquidation rules if it ever wants to uncheck that box and go back to being treated as a partnership or sole proprietorship. See Corporate Liquidations, page 18-19.

My thoughts exactly................................

[BHoffman]

I'm so glad you guys weighed in before I've even really started this return. Thanks so much for your input and I appreciate your patient replies.

[BHoffman]

This is harder than I thought it would be

[BHoffman]

Is allowed between the corporation and the shareholder.

Hi veritas - I'm looking at Sec 336(d)(A). I'm understanding it to mean that loss is allowed upon complete liquidation unless it is (i) not pro-rata ( only one shareholder here) or is (ii) non-qualified property ( this shareholder did not make any capital contribution of property within the 5 year period).

http://www.taxalmanac.org/index.php/Internal_Revenue_Code:Sec._336._Gain_or_loss_recognized_on_property_distributed_in_complete_liquidation

Am I misunderstanding this? Thanks for advice.