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,
global intangible low-taxed income,
beneficiary,
Treas. Reg. 1.1361-1(g)(1)(i),
Form 8833,
controlled foreign corporation,
§7701(b)(1)(B),
TCJA,
Treas. Reg. §301.7701(b)-7,
CFC,
§7701,
Tax Cuts and Jobs Act,
INTL-121-90,
SSN,
Office of the Chief Administrative Hearing Officer,
s corporation,
§1361(a)(1),
OCAHO,
c corporation,
§1361(b)(2)(C),
§1362(d)(2),
Immigration Reform and Control Act of 1986,
GILTI,
§1362(a),
shareholders,
Immigration Act of 1990,
nonresident alien,
Treas. Reg. §301.7701(b)-7(a)(4),
double taxation,
electing small business trust,
ITIN,
§957,
foreign bank account,
ESBT,
small business,
§552,
green card test,
tax treaty,
partnerships,
substantial presence test