A quarterly magazine from the National Association of Enrolled Agents
Spring 2025 vol.43 no.1
Unmasking the Myths: Who Can Truly Be a Shareholder in an S Corporation?
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
Tax Policy 101
Tax Policy

Tax Policy 101

Those of you who have made the pilgrimage to the Internal Revenue Services’ (IRS) headquarters, which I have quasi-affectionately referred to as “the big house,” (or by its address, 1111 Constitution Avenue) may have noted the Oliver Wendall H... Robert Kerr, EA

Nov/Dec 2021, Tax Policy, Internal Revenue Code, international, GILTI, tax policy, global intangible low-tax income, foreign derived intangible income, FDII, required minimum distribution, RMD, Registered Tax Return Preparer program, RTRP, Loving v. Commissioner
What President-Elect Joe Biden’s Tax Policies Could Mean for You
Capitol Corner

What President-Elect Joe Biden’s Tax Policies Could Mean for You

President-elect Joe Biden has developed a comprehensive plan to reorder the nation’s tax laws. In short, he would raise taxes on households over $400,000 and on corporations and provide myriad programs and tax cuts for working- and middle-class Americans. His ab... Jeffery S. Trinca and Michelle McCaughey

Jan/Feb 2021, Capitol Corner, Tax Cuts and Jobs Act, COVID-19, Biden, GILTI, payroll tax