LIFO Recapture on C-to-S Conversions: Filling the Gaps and Ameliorating the Deficiencies of Section 1363(d)
Prior to the enactment of section 1363(d) in 1987, the conversion of a C corporation to S corporation status was, with rare exception, considered to be a nonevent for tax purposes. None of the gain or loss built into the value of the converting corporation's assets was recognized...