Question

The net gain that an S corporation would recognize if it sold each asset at its fair market value on the first day after converting from a C corporation to an S corporation is the:

a. Built-in Gains Tax
b. Ordinary Business Income
c. Accumulated Earnings and Profits (E&P)
d. Section 1231 Gain

Answer 1

The correct answer is the a. Built-in Gains Tax, which applies to the appreciated asset value accumulated during the previous C corporation status if the S corporation sells the assets soon after the conversion.

Step-by-step explanation:

When a C corporation converts to an S corporation, it may have to deal with the tax implications of the built-in gains on its assets. If the S corporation were to sell assets at a gain, which had appreciated in value during its time as a C corporation, it may be subject to the Built-in Gains Tax. This tax is designed to ensure that the corporation pays tax on the appreciation of assets that occurred while it was a C corporation, thus preventing the avoidance of corporate-level tax by changing its tax status.

The built-in gains tax is imposed at the corporate level, even though S corporations generally pass income directly to shareholders. It is important to note that the built-in gains tax does not apply if the S corporation waits to sell the assets until after a certain period, usually five years after conversion from C corporation status. Answer choice (a) is the correct one in this context.