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An S corporation (or S Corp), for United States federal income tax, is a closely held corporation (or, in some cases, a limited liability company (LLC) or a partnership) that makes a valid election to be taxed under Subchapter S of Chapter 1 of the Internal Revenue Code. [1] In general, S corporations do not pay any income taxes. Instead, the ...
Revenue rulings are published in both the Internal Revenue Bulletin and the Federal Register. The numbering system for revenue rulings corresponds to the year in which they are issued. For example, Revenue Ruling 79-24 was the twenty-fourth revenue ruling issued in 1979.
Other relevant sources are Revenue Ruling 2003-38, which entails whether an expansion of a corporation's business constitutes a new or continuing business under Reg. 1.355-3(b)(3)(ii). 4) The mission of the device limitation has been to prevent the conversion of ordinary dividend income into preferentially taxed capital gain through a bailout ...
The text of the Internal Revenue Code as published in title 26 of the U.S. Code is virtually identical to the Internal Revenue Code as published in the various volumes of the United States Statutes at Large. [3] Of the 50 enacted titles, the Internal Revenue Code is the only volume that has been published in the form of a separate code.
This tax is imposed at the same rate as the tax on business income of a resident corporation. [72] The U.S. also imposes a branch profits tax on foreign corporations with a U.S. branch, to mimic the dividend withholding tax which would be payable if the business was conducted in a U.S. subsidiary corporation and profits were remitted to the ...
The origin of the current rate schedules is the Internal Revenue Code of 1986 (IRC), [2] [3] which is separately published as Title 26 of the United States Code. [4] With that law, the U.S. Congress created four types of rate tables, all of which are based on a taxpayer's filing status (e.g., "married individuals filing joint returns," "heads of households").
Internal Revenue Code § 162(a) INDOPCO, Inc. v. Commissioner , 503 U.S. 79 (1992), was a United States Supreme Court case in which the Court held that expenditures incurred by a target corporation in the course of a friendly takeover are nondeductible capital expenditures.
A corporation may be chartered in any of the 50 states (or the District of Columbia) and may become authorized to do business in each jurisdiction it does business within, except that when a corporation sues or is sued over a contract, the court, regardless of where the corporation's headquarters office is located, or where the transaction ...