CHOICE OF ENTITY & CONVERSATION OF BUSINESS ENTITIES AFTER THE OBBBA

Choice of entity is one of the most interesting – and important – issues in US and Massachusetts income taxation and in professional tax practice in 2026.

The simple summary is that the decision is NOT SIMPLE AT ALL!  First, the exploding popularity of Qualified Small Business Stock (“QSBS”) means that more corporations, and especially more start-up corporations, are choosing to be (or become) C corporations than at any time since 1986.

But at the same time, closely held private businesses continue to choose strongly (and perhaps overwhelmingly in the aggregate) to operate as pass-through entities, either as S corporations or as LLCs taxable as partnerships.  In turn, choosing between an S corporation and an LLC for any specific client is often nuanced and complicated in many cases, and an interesting decision to discuss in all cases.

Yet another wrinkle to consider is the conversion decision – when is the right time to convert an existing LLC into a C Corporation (eligible to issue QSBS), or to convert an S corporation into an LLC taxable as a partnership via an “F” reorganization under Rev. Proc. 2008-18 and related guidance?

This webinar will provide strong and clear guidance on how to make all these decisions, both choosing the initial form of entity (C corporation v. S corporation v. LLC), and then later deciding whether to convert the LLC into a C Corporation and issue QSBS, or (if it holds real restate) possibly convert the LLC into a Tenancy in Common eligible to engage in a Like Kind Exchange under Code Section 1031.

Come enjoy (and participate in) a lively discussion and debate on this classic and timeless tax question.

Registration Form: 2026 Fall CPE Registration Form