1120-US: Allocating specific S Corporation items to the shareholder (FAQ)

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Question

Can I specifically allocate S Corporation items to the shareholders?

Answer

No. Per IRC section 1377(a)(1), items of income, gain, loss, deduction, or credit are allocated to the shareholder on a per share, per day basis. S Corporation items cannot be specifically allocated to shareholders.

Per IRC section 1377(a)(2), if any shareholder terminates their entire interest in the S Corporation, with the consent of all affected shareholders the S Corporation can elect to have the rules providing for pro rata shares apply as if the tax year consisted of two tax years.

The S Corporation can also elect to treat the year as if the year consisted of separate taxable years in the case of a qualifying disposition under IRC Regulation 1.1368-1(g)(2).

For more information, see Shareholder termination and qualifying dispositions FAQs.

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