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As a result of this deemed liquidation, the subsidiary's taxable year, and its separate existence for federal tax purposes, end at the close of the day before the QSub election is effective.
The tax treatment of this deemed liquidation is determined under all the relevant provisions of the tax law, including the application of the step transaction doctrine.
Alternatively, if the transaction fails to qualify as a reorganization, it may be fully taxable.
Two simple steps which appeared to be tax free thus become one single step, which may be taxable, in whole or in part.
Under a QSub election, the separate existence of the subsidiary is disregarded, and its assets, liabilities, and items of income, deduction and credit are instead treated as owned or derived by the S corporation directly.
The QSub election thus transforms a 100%-owned subsidiary from an entity separately recognized as a corporation for federal income tax purposes, into a branch or division of the S corporation parent with no separate existence or status for income tax purposes.This letter outlines important provisions of the new regulations you should be aware of when planning QSub transactions.It is important to note that, due to the operation of the final regulations' transitional relief rules, some taxpayers may be facing a March 15, 2000 deadline for taking action.The new regulations address many of these issues but, as is evident from the points discussed below, there remain important areas in which the use of a QSub continues to raise planning opportunities, as well as potential pitfalls.As a result, while the QSub appears in many respects to represent an important simplification there remain, even after the final regulations, significant areas in which oversimplification can be dangerous.However, a QSub election can only be made when the electing parent corporation is an S corporation.