Form 8832 Archives | EA Journal

Feature Article

The Debate Between S Elections and C Elections: The Overlooked Case of Profit Projections

Few decisions in entity structuring spark more debate among tax practitioners than whether a closely held business should elect S corporation or C corporation treatment. Online forums, continuing educati... Elan Becker, EA

Spring 2026, Feature Article, TCJA, Tax Cuts and Jobs Act, s corporation, c corporation, §199A, AMT, Alternative minimum tax, Form 2553, Form 8832, specified service trade or business, SSTB, S election, C election, entity choice, qualified business income deduction, QBID, §1202, qualified small business stock, QSBS, §1361, §1379, §1362, Fact Sheet FS-2008-25, net investment income tax, NIIT, accumulated earnings tax, AET, §531, §1372, David E. Watson, P.C. v. United States

ICYMI

A roundup of recent discussions from the NAEA WebBoard. QUESTION #1: I have a client who rents out land for a solar farm. I read that a land rental cannot qualify for the qualified business income (QBI) deduction but am trying to find a ... Tynisa Gaines, EA, and Patrick D. Dimmitt, EA

Winter 2024, ICYMI, s corporation, rental, QBI, partnership, depreciation, Schedule C, Schedule K-1, §6221(b), LLC, Form 1065, §121, Form 1120-S, Rev. Proc. 2013-30, §357(c), §351, Form 8832, Reg. §1.469-2T(f)(3), §167, qualified business income, §1016, Rev. Proc. 2019-38, Reg. §1.199A-1(b)(14), solar, Treas. Reg. §301.6221(b)-1, §4.02(6), §5.02, Reg. §1.351-3, §121(d)(10), §1.1250-3(a)(3), Reg. §1.1245-2(a)(4) a, §1250(b)(3), §121(d)(6), Rev. Proc. 2002-69, Schedule SE, Schedule F, §761(f)(2)(B), Badaracco v. Commissioner, §4.03, §721, qualified joint venture, §25D(e)(8), Form 13844, direct debit installment agreement, DDIA, QJV

Feature Article

Will Your Client’s LLC Operating Agreement Make an Election Under Subchapter S Invalid?

Organization of a business enterprise as a limited liability company (LLC) has a number of advantages. In addition to ease of formation, state LLC acts dispense with many of the formalities required for corporations and wide latitude is given to... Patrick D. Dimmitt

Fall 2024, Feature Article, s corporation, employee, election, LLC, Form 1120-S, safe harbor, debt, limited liability company, Form 8832, §1362(f), stock, §1361(1)(D), Treasury Regulation §1.1361-1(l)(1), §338(h)(10), Subchapter S, Private Letter Ruling 201949009, Private Letter Ruling 201930023, Private Letter Ruling 202315005, Private Letter Ruling 202110010, §704, §83(b), Treas. Reg. §1.704-1(b)(2)(ii)(b)(2), Private Letter Ruling 202111011, Private Letter Ruling 202310001, Uniform Limited Liability Company Act, ULLCA, §105(b), Rev. Proc. 2022-19, §3.06, Corporate Governing Provision Statement, §3.06(d), Treas. Reg. §1.704-1(b)(2)