AN 92(7)
Unreasonable Compensation Of S Corporation Shareholders
The Department of Revenue Services has been studying the issue of the unreasonable compensation of officers and employees of an S corporation. This issue directly affects the corporation business tax liability of the S corporation in that the amount of its net income that is subject to corporation business tax is computed by deducting compensation of its officers and employees.
After careful consideration, the Department of Revenue Services is making known in this Announcement that it does not intend to raise the unreasonable compensation issue in corporation business tax audit examinations of S corporations for taxable years beginning before January 1, 1993. However, the Department may raise the issue in corporation business tax audit examinations of S corporations for taxable years beginning on or after January 1, 1993, irrespective of whether the Internal Revenue Service has raised the issue.
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AN 92(7)
Corporation business tax
Issued 12/10/92