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new irs rulings approve rescission transactions that change
by SI Banoff 2006 For various non-tax reasons (including IPOs), owners of pass-through entities might consider con- verting those entities into a C corporation.
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An owner can enter into an agreement with the PTE to pay the tax otherwise required to be withheld by the PTE. The agreement may be made by completing Form RPD
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Corporations and Partnerships
Distributions of money to the owners, to the extent they do not exceed pass-through income, will be generally non-taxable. This is because the income that
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