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Oct 12, 2021 21:51
3 yrs ago
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English term
a qualified subchapter S subsidiary
English to Russian
Law/Patents
Law: Contract(s)
Из договора купли-продажи акций:
WHEREAS, the Company will elect to be treated as a qualified subchapter S subsidiary for U.S. federal income tax purposes, (steps (i) through (iv) collectively, the “F Reorganization”);
WHEREAS, the Company will elect to be treated as a qualified subchapter S subsidiary for U.S. federal income tax purposes, (steps (i) through (iv) collectively, the “F Reorganization”);
Discussion
https://www.law.cornell.edu/uscode/text/26/subtitle-A/chapte...
26 U.S. Code Subchapter S
Получается "квалифицированная дочерняя компания в соответствии с Подразделом S Главы 26 Свода законов США"?
https://www.thetaxadviser.com/issues/2012/aug/casestudy-aug1...
A qualified subchapter S subsidiary (QSub) is a subsidiary corporation 100% owned by an S corporation that has made a valid QSub election for the subsidiary (Sec. 1361(b)(3)(B)). Because a QSub’s separate existence is ignored, transactions between the S corporation parent and QSub are not taken into account, and items of the subsidiary (including accumulated earnings and profits, passive investment income, and built-in gains) are considered items of the parent. The QSub election terminates the QSub’s former identity as a separate entity for federal tax purposes. Thus, a final income tax return must be filed. This final return generally includes the deemed liquidation transaction.
A QSub is normally treated as a disregarded entity for all purposes of the Code (Secs. 1361(b)(3)(A)(i) and (ii)). However, the IRS is authorized to treat it as a separate entity for certain purposes (Sec. 1361(b)(3)(A)).