Tax Court 
Do Disproportionate Distributions Terminate an S Corporation Election?
S corporations cannot have more than one class of stock.i Based on this prohibition, many tax professionals believe that an S corporation that makes disproportionate distributions to shareholders terminates its S corporation e... Thomas A. Gorczynski, EA, USTCP
Feature Article
Unmasking the Myths: Who Can Truly Be a Shareholder in an S Corporation?
Revisiting the Basics of the S Corporation: Nonresidents as Shareholders Small business corporations are more popular than ever. You hear about them on social media, and among the tax community. Indeed, sm... Fernando Juarez, EA, and Edgar Gonzalez, EA
Spring 2025,
Feature Article,
TCJA, Tax Cuts and Jobs Act, s corporation, c corporation, GILTI, nonresident alien, ITIN, small business, partnerships, beneficiary, controlled foreign corporation, CFC, SSN, §1362(d)(2), shareholders, double taxation, foreign bank account, green card test, substantial presence test, Treas. Reg. 1.1361-1(g)(1)(i), §7701(b)(1)(B), §7701, Office of the Chief Administrative Hearing Officer, OCAHO, Immigration Reform and Control Act of 1986, Immigration Act of 1990, electing small business trust, ESBT, tax treaty, global intangible low-taxed income, Form 8833, Treas. Reg. §301.7701(b)-7, INTL-121-90, §1361(a)(1), §1361(b)(2)(C), §1362(a), Treas. Reg. §301.7701(b)-7(a)(4), §957, §552