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https://completemarkets.com/company/CompleteMarkets/Articles/content-package/IMMS-Library/TabCategory/article-post/1530/LEGAL-OUTLINE-FOR-CALIFORNIA-AGENCIES-CHAPTER-1/
... sale of expirations at the corporate level without a double tax. The purchased expirations can then be amortized over 15 years by the buyer. However, better deductibility of payments for the agency can be generated in other ways, such as a partnership liquidation plan. Also, if the expirations are owned by the corporation, and an individual owner wants to leave with his expirations, it is difficult to class='cm-highlight'>spin off expirations and avoid triggering a capital gains tax. The stock could also be owned by a partnership. This permits essentially fully deductible liquidation payments to a retiring partner by the remaining partners. It allows easier ownership interest revisions according to production, if the partners want this. However, it prevents a subchapter S election. This organizational structure should be formalized by an agreement between the corporation and ... acquired by a larger brokerage, particularly one listed on a national exchange. 1.2.5 Subchapter S corporation. The Subchapter S corporation is an ordinary business corporation which qualifies for and has elected Subchapter S treatment. It is taxed like a partnership in most respects. Not all corporations can qualify for subchapter S status. For example, it can have no more than 35 shareholders, it can have only one class of stock, and the shareholders must be individuals (or estates or certain trusts) . This means that a partnership can't hold S corporation stock. Limited liability of shareholders is a feature of an S corporation, just as for a C corporation. Passthrough taxation of income to shareholders is the major feature of an S Corporation. An S corporation for the most part passes income and deductions through ...

https://completemarkets.com/Article/article-post/1530/LEGAL-OUTLINE-FOR-CALIFORNIA-AGENCIES-CHAPTER-1/
...is expirations, it is difficult to class='cm-highlight'>spin off expirations and avoid triggering a...