To amend the Internal Revenue Code of 1986 to provide for S corporation reform, and for other purposes.
TABLE OF CONTENTS:
Title I: Eligible Shareholders of an S Corporation
Title II: Qualification and Eligibility Requirements of S
Corporations
Title III: Taxation of S Corporation Shareholders
Title IV: Effective Date
Subchapter S Revision Act of 1999 - Title I: Eligible Shareholders of an S Corporation - Amends the Internal Revenue Code to allow certain members of a family to be treated as one shareholder of an S corporation (electing small business corporation). Permits nonresident aliens to be S corporation shareholders if the corporation is engaged in a U.S. trade or business. Subjects such aliens' effectively-connected U.S. income to withholding tax.
Title II: Qualification and Eligibility Requirements of S Corporations - Prohibits, with respect to S corporations, treating: (1) qualified preferred stock as a second class of stock; and (2) a person as a shareholder by reason of holding such stock.
(Sec. 202) Permits financial institutions to hold convertible (safe harbor) debt.
(Sec. 203) Repeals: (1) the characterization of excessive passive investment income as a termination event; and (2) the passive income capital gain category.
(Sec. 205) Permits: (1) an S corporation to make charitable contributions of inventory and scientific property; and (2) S corporation shareholders to increase the basis of their stock by the excess of the charitable contribution over the property's basis.
(Sec. 206) Makes other-than health insurance fringe benefits nontaxable for S corporation two-percent shareholders.
Title III: Taxation of S Corporation Shareholders - States that a loss recognized by a shareholder in a complete liquidation of an S corporation shall be treated as an ordinary loss to the extent the shareholder's stock basis is attributable to ordinary income from such liquidation.
Title IV: Effective Date - Sets forth the effective date for provisions of this Act.
Read twice and referred to the Committee on Finance.
Introduced in House
Introduced in House
Sponsor introductory remarks on measure. (CR E196-197)
Referred to the House Committee on Ways and Means.
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