Next, S corp exemption from tax on built in gains - the rules/exemptions per my becker notecard followed by my question... -
1. the sale or transfer does not occur with 10 years of the first day of first year that S corp election is made. It just went form C corp to S corp - so how could it wait 10 years, the transfer occurred when the election was made, just like the transfer of the all the other financial statement accounts.
2. S corp was never a C corp. um, its only a built in gain if it was transferred from a C corp.. so how could it not have been a C corp?
3. S corp can demonstrate that the distributed asset was acquired after the S election. If it was bought after the S election, why would it even be a concern for a built in gain?
could be too late at night.. could be reading into it too much, in general the built in gain concepts seem straightforward in the questions, this notecard just confused me.
FAR 11/13 - 78, BEC 1/13 - 82, AUD 2/23 - 94, REG 5/15 - 86
