id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-443	August, Jerald David	Benefits and Burdens of Subchapter S in a Check-the-Box World	2022	52	.pdf	application/pdf	24080	1390	58	Indeed, the conduit rules of Subchapter K offer far greater structural and transactional flexibility, with the exception of an inability to engage in tax-free reorgani- zations, and also offer more income deferral techniques than Subchapter S. Moreover, in not providing Subchapter S corporations with the same organizational flexibility as partnerships-by, for example, prohibiting nonresident alien shareholders and preferred stock-Congress has restricted S corporations and their shareholders in their access to capital. 311 a. Rules for S Corporations .........	cache/ftr-443.pdf	txt/ftr-443.txt