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A. Shareholder Basis
Section 301.6245-1T, Temporary Proced. & Admin. Regs., 52
Fed. Reg. 3003 (Jan. 30, 1987), provides a laundry list of
subchapter S items; i.e., items that are required to be taken
into account for the taxable year of an S corporation, that the
Secretary has determined are more appropriately determined at the
corporate level than at the shareholder level. Specifically,
section 301.6245-1T(a)(5), Temporary Proced. & Admin. Regs.,
supra, includes in such list of subchapter S items the following:
(5) Items relating to the following transactions,
to the extent that a determination of such items can be
made from determinations that the corporation is
required to make with respect to an amount, the
character of an amount, or the percentage of stock
ownership of a shareholder in the corporation, for
purposes of the corporation's books and records or for
purposes of furnishing information to a shareholder:
(i) Contributions to the corporation; and
(ii) Distributions from the corporation.
In sum, section 301.6245-1T(a)(5), Temporary Proced. & Admin.
Regs., supra, provides that subchapter S items include items
related to shareholder contributions and corporate distributions
to the extent that a determination of such items can be made from
determinations that the corporation is required to make with
respect to the character or amount of a contribution or
distribution for purposes of the corporation's books and records
or for purposes of furnishing information to a shareholder.
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