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At the 2016 Summer Tax Seminar it was said that for tax year 2016,the recognition period is 7 years for S corporations that made S elections in 2009 and 2010. I don't understand this statement. When you read IRC 1374 it seems to say the recognition period is now 5 years. So for example if an S corporation had realized built in gain in tax year 2016 but had been an S corporation for 60 months or more at the time the built in gain was realized, then the built in gains tax would not apply since the S corporation was past the recognition period. Spidell seems to be saying the recognition period is not 5 years, in all cases, for tax years 2016 and beyond.