Stubs for Business Entities

From The Shelf Project

• Amend Section 318(a)(1) to conform to Section 267(c)(4) and then amend both to include the spouses of all such family members.

• Eliminate the ten year recognition period limitation on the tax imposes on built-in gains of C corporations that convert to subchapter S under IRC 1374.  Currently no tax is due on built in gains realized more than ten years after conversion.
• Eliminate graduated income tax rates for C corporations, trusts and estates.  This is something already done for personal service corporations.
• Impose an entity level withhholding tax on pass through business entities which is allocated to partner/members in the same manner as income.