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For a corporation to be considered a personal service corporation by the IRS, the employee/owner must perform at least 20% of the personal services themselves, and must also own at least 10% of the outstanding stock in the testing period. An income test requires that employees must spend at least 95% of their work time on qualified services.
The creator of the corporation is typically the sole shareholder, [1] and thus the corporation is used as a means to reduce their personal liability, protect their assets and exploit taxation advantages. Loan-Out corporations are especially prominent in the entertainment and professional sports industries, as the creator's services are ...
The category of a qualified dividend was created with the Jobs and Growth Tax Relief Reconciliation Act of 2003 ("JGTRRA"), that reduced all taxpayers' personal income tax rates and cut the tax rate on qualified dividends from the ordinary income tax rates to the lower long-term capital gains tax rates. At the same time the bill reduced the ...
The asset test is met if 50% or more of the foreign corporation's average assets (as defined in the IR Code) produce, or could produce passive income, or are assets (such as cash and bare land) that produce no income. The test is applied based on the foreign corporation's adjusted basis, for U.S. tax purposes, of the assets, or at the election ...
Holding: Personal jurisdiction for claims regarding a website require application of the Calder test to establish "minimum contacts" as defined by Int'l Shoe. Twentieth Cent. Fox Film Corp. v. iCraveTV, 53 U.S.P.Q.2d 1831 (W.D. Pa. 2000). [19] iCraveTV was a Canadian Internet startup that offered real time streaming of television over the Internet.
"Engaging in qualified research" means the direct conduct of research and development. "Directly supervising qualified research" is the first-line supervision of qualified research. This does not include the higher-level managers to whom the first-line supervisors report. "Supporting qualified research" includes an employee's time spent aiding ...
Qualified Small Business Stock (QSBS) is a tax incentive to drive the investment and founding of small businesses in the United States of America. [1] The QSBS regulations are under U.S. Code Section 1202 [2] of the Internal Revenue Code (IRC). QSBS is a tax exemption on a federal, and in some cases, a state level. [3]
A foreign eligible entity that became an association taxable as a corporation under the foreign default rule described below. A foreign corporation that is not identified as a corporation under Treasury regulations §301.7701-2(b)(8). If a foreign corporation is not identified on the list included in these regulations, it qualifies as an ...