Dover Corporation and Subsidiaries - Page 15

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          as a corporation * * * can elect its classification for federal             
          tax purposes as provided in this section”.                                  
               In pertinent part, section 301.7701-3(g)(1)(iii), Proced. &            
          Admin. Regs., provides:                                                     
                    (iii) Association to disregarded entity.  If an                   
               eligible entity classified as an association elects * *                
               * to be disregarded as an entity separate from its                     
               owner, the following is deemed to occur:  The                          
               association distributes all of its assets and                          
               liabilities to its single owner in liquidation of the                  
               association.                                                           
               Section 301.7701-2(a), Proced. & Admin. Regs., states that,            
          “if * * * [an] entity is disregarded, its activities are treated            
          in the same manner as a sole proprietorship, branch, or division            
          of the owner”.                                                              
               Under section 301.7701-3(c)(1)(i), Proced. & Admin. Regs., a           
          classification election, including an election to change                    
          classification, is made by filing a Form 8832 with the IRS                  
          service center designated on that form.  Under subdivision (iii),           
          the election is effective “on the date specified by the entity on           
          Form 8832" if, as in this case, one is specified.                           
               Under section 301.7701-3(g)(3)(i), Proced. & Admin. Regs.,             
          an election to change classification “is treated as occurring at            
          the start of the day for which the election is effective”, and              
          “[a]ny transactions that are deemed to occur * * * as a result of           
          a change in classification [e.g., in the case of a change in                
          classification from association to disregarded entity, the deemed           
          liquidation] are treated as occurring immediately before the                




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