Revenue Ruling 14-001: Qualified Subchapter S Subsidiary Exclusion

The purpose of this Revenue Ruling is to determine whether a domestic corporation, that was incorporated outside of Louisiana, that is a one hundred percent owned subsidiary of a parent corporation may amend Louisiana income tax returns in order to apply the QSub exclusion, provided that the parent corporation files original Louisiana income and franchise tax returns, including all of the income of the QSub in the parent corporations net income.

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Conclusion:

Neither La. R.S. 47:287.732.1 nor RIB 04-003 provide any prohibition against the filing of amended returns in order to claim the QSub exclusion.  In fact, according to RIB 04-003, the QSub exclusion can be “made by simply filing returns” that follow preferred methods.

Click here to read the full text of Revenue Ruling 14-001, including analysis of a hypothetical scenario supporting the conclusion.

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