S corporation AAAs and C corporation AE&Ps. (accumulated adjustment accounts, accumulated earnings & profits): An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on January 1, 1993. The length of the article is 576 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Positive and negative accumulated adjustment accounts of merged subchapter S corporations cannot be used to offset one another according to the IRS. IRC 1368 which derives from Letter Ruling 9002051 mandates this in line with IRC 381(c)(2). This is consistent with treatment of accumulated earnings and profits of subchapter C corporations, which are also prohibited from offset use under IRC 381(c)(2)(B).

Citation Details
Title: S corporation AAAs and C corporation AE&Ps. (accumulated adjustment accounts, accumulated earnings & profits)
Author: Laura M. MacDonough
Publication:The Tax Adviser (Magazine/Journal)
Date: January 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n1 Page: 26(2)

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