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Posts Tagged ‘Section 1374’

Built-In Gain Tax Not Triggered By S Corporation Conversion of LLC Interest

Published: October 18th, 2017

Stephen R. Looney

An S corporation that was previously a C corporation is subject to the built-in gains tax under Section 1374 if appreciated assets held by the corporation (measured from the beginning of the S corporation’s first taxable year) are disposed of during the “recognition period.”  The built-in gains tax is imposed at the corporate, rather than […]