Instead, the money has simply followed a circular pattern, from S Corporation 1 to S Corporation 2 to A and back to S Corporation 1.
Alternatively, can A assume the debt S Corporation 1 owes to S Corporation 2 in return for a promissory note from A to S Corporation 2?
Can S Corporation 1 repay the loan to S Corporation 2, who in turn loans the money to A, who in turn loans the money back to S Corporation 1?
Rather than fund the operations of S Corporation 1 with a loan directly to S Corporation 1, A used his profitable related corporation, S Corporation 2, to loan amounts to S Corporation 1.
Example: A owns 50 percent of the stock of an S corporation (S).
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The note between the two parties was a legitimate debt of S Corporation 1 and an asset of S Corporation 2.
Self-employment activity generally includes ownership and operation of a sole proprietorship, Limited Liability Company (LLC), C Corporation, S Corporation, and Limited Partnership where the business intends to generate revenue for profit and make significant contributions to the plan.
Under current law, S corporation shareholders only increase their basis in the S corporation for loans made directly to the corporation by the shareholder.
Unfortunately for A, as scores of court cases have held, the loan from S Corporation 2 does not give A debt basis in S Corporation 1, even though A owns 100% of both corporations.
It has to be said that the company's standards are no better nor worse than most every other large U.S. corporation's, and that Disney complies with Securities and Exchange Commission guidelines.
At first, they recommended the safest route: have S Corporation 2 distribute enough cash to A so he could contribute it to S Corporation 1 and increase his basis.
So the accountants looked to another alternative, recommending that A distribute the note receivable from S Corporation 2 to A, who in turn would contribute the note to S Corporation 1.
If he were to step down pending resolution of the crisis at News Corporation, it is likely he would be replaced by BSkyB's senior non-executive director, Nick Ferguson - who in effect played that role in BSkyB's board discussions over News Corporation's attempt to purchase all of BSkyB.
This is so because it can be argued that the S corporation would not generate any revenue without the personal services of its shareholders, and thus the entire amount of S corporation income should be paid out in salary.
There might also have been insurmountable problems to qualifying the corporation as an S corporation, such as uncooperative non-qualifying shareholders.
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It is not a federally exempt nonprofit corporation, a C corporation, an S corporation, a limited liability company, a general or limited partnership.
To illustrate, if a taxpayer owns an interest in an S corporation that earns a certain amount in income and distributes half the sum to the taxpayer, the taxpayer would include the amount in his calculation of the NII sum if he does not materially participate in the S corporation.
KYOTO, Oct. 17, 2012 - Kyocera Corporation(NYSE:KYO)(TOKYO:6971) today announced the release of the DIGNO S smartphone, which is compatible with KDDI Corporation's recently launched (September 2012) high-speed 4G LTE network.
Culture Secretary Jeremy Hunt's appointment to handle News Corporation's bid to buy BSkyB "was not some rushed, botched, political decision", PM David Cameron has said.
James Murdoch's hopes of keeping News Corporation's planned takeover of 100% of British Sky Broadcasting away from the scrutiny of the media regulator, Ofcom, look set to be dashed.
Done right, it's a way to powerfully distinguish your corporation's image, advance its interests and enhance its competitive position.
Sandberg and Google.org head Larry Brilliant drew on people they knew from their earlier lives (at, respectively, global health and the U.S. Treasury) to head the corporation's big initiatives.
His Culture Minister, Tessa Jowell, who is overseeing the review of the BBC's charter, says it's impossible for the government to threaten the corporation's independence.
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BBC's governors issued a statement unreservedly standing by the corporation's journalism.
If a taxable corporation converts into an S corporation, the conversion is not a taxable event.
Her corporation is an S-corporation, so she files and pays her corporate income taxes on her individual return.
He also said that "producers of 'Panorama' seem not to have learned any lessons from recent BBC scandals, " an apparent reference to the BBC's handling of abuses police say were carried out on the corporation's premises by the late TV presenter and radio host Jimmy Savile.
In this year's MacTaggart Lecture, Mr Thompson must try to win round the corporation's critics, including some of those commercial rivals and politicians.
The chief executive of the Royal Opera House and the BBC's former director of news, Tony Hall, has been appointed the corporation's new director general.
In a statement, it said the man, who worked in the Met's Territorial Policing command, was arrested following the release of information by News Corporation's Management and Standards Committee (NCMSC).
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