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Form 8594 online Columbus Ohio: What You Should Know
This is also applicable to any transaction under Section 1041 of the Internal Revenue Code. For reporting purposes, each of the Company and the Seller (the Company and Seller) will report any sale or exchange of shares of its Common Stock or any other assets (whether on an exchange basis) of the Company or of any other S corporation (the Seller) made by the Company or the Seller to persons (each, a “S” Person). If any sale or exchange of shares of Company Common Stock or other assets is made by the Company or the Seller to S persons, that sale or exchange will be treated as made by the Company and the Seller to any person (whether S) that is an “other S corporation” (as defined in Section 1361(b) of the Code), which means a corporation that does not qualify for the application of Section 1041 of the Code in circumstances other than a corporate reorganization. The terms “S corporation” and “other S corporation” refer to shareholders of a corporation unless such terms are defined in the applicable section of the Code. Therefore, any such other person, if any, that is described above will be treated as a person meeting the definition of the term “S corporation” (as defined in Section 1361(b) of the Code) for purposes of this Section. For this purpose, an S corporation does not include any corporation that is an S corporation as the result of a merger, consolidation, reorganization, recapitalization (within the meaning of Section 355 of the Code), or similar transaction in which the stock of the surviving S corporation acquired after the transaction by means of a stock dividend (or similar distributions) are received by a controlled person, unless (A) such stock is held by such person solely for the beneficial interests of such person; (B) no significant corporate purpose is served by the control held by such person; and (C) all the shares and securities representing substantial economic benefit (within the meaning of Section 280A of the Code) of such company are disposed of to persons with whom such controlled person does not deal at arm's length (and such other S corporation is described in the Section 1041(a)(4) or (b)(8) material in respect of such transaction).
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