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163(j) opt-out election re: aggregation of LLC/Scorp interests

Client owns >50% shares in multiple LLC/Scorps. None of the entities gross 25 million each, but aggregated the client is way over 25 million gross. On what level and how would we elect the opt-out since each business is automatically exempt due to being under 25 million gross income? Any help would be welcome! Latest regs have not given me a definitive answer but perhaps I missed something!

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If You are aggregated group because of the ownership issues than total receipts of that group is >25mill., in order to opt out of the limitation you make the election on any of the entities that you need to opt out. No need to on each company unless you choose to. The election on Lacerte is done manually. The change to ADS depreciation is then done manually also.


Hope this helps. A royal pain.

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