H corporation's
http://stnhcorp.com/eng/about_1_1.html WebMar 27, 2024 · The limits of 338(h)(10) and 336(e) for an S corporation can be partially sidestepped by having the corporation contribute its assets to a LLC or partnership subsidiary (either directly or through an “F reorganization”) and then having the S corporation sell a partial interest in the subsidiary using a 754 election. This avoids the …
H corporation's
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