In the case of a corporation, the calculation of the tax base includes a subtraction for "[d]efinite and accrued legal liabilities." Where debt is owed by a corporation to an affiliated noncorporate
business entity, the language in the Bill would require the creditor noncorporate
business entity to add this debt to its tax base.
Probably the most popular form of
business entity today is the LLC.
The model we have described focuses on four areas where the medical practice organization is vulnerable in a rapidly changing environment and suggests what the medical practice needs to do to improve its prospects for survival as a
business entity in the health care system.
A
business entity would be considered resident in a tax jurisdiction if, under the jurisdiction's laws, the
business entity is liable to tax based on place of management, place of organization, or other similar rules, but not just because it is liable for tax on income or capital located there.
With the introduction of the Single Business Tax, the State of Michigan was pursuing four laudable goals: alleviating a budget shortfall owing to the recession of the early 1970s, providing a more stable source of tax revenue than had previously been collected, promoting economic efficiency by encouraging investment in the state, promote economic efficiency by taxing all forms of
business entity, regardless of form, and easing the compliance burden by providing a single tax that was easier to administer than the seven taxes that it replaced.
The new tax legislation has changed the choice of
business entity environment for private companies, and privately held C corps might benefit from electing S corp status.
Pros: This
business entity is best suited for a general partner looking for a silent partner(s) not involved in the day-to-day operation of the business (for example, an investor).
Alternatively, the lower tier company may be a QSSS, an arrangement that preserves the pass-through nature of the
business entity. The parent company can achieve the same result by structuring the lower tier subsidiary as an LLC, provided it is chartered in a state that permits one-member companies.
Should you file a
Business Entity Return even though you don't have the money to pay?
* The
business entity is an eligible entity under Regs.
* Acquisition of a 10 percent or greater interest in a
business entity with U.S.
[section] 1.263(a)-5, applicable to costs incurred to facilitate the acquisition of a trade or business, a change in the capital structure of a
business entity, and certain other transactions.
