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Loophole

§1361(b)(3) QSub Election

Roll multiple S-corps under one parent — single tax return, unlimited subs.

Overview

A Qualified Subchapter S Subsidiary (QSub) election lets an S-corp own 100% of another S-corp and treat it as a disregarded entity for tax purposes. One consolidated K-1, one return, unlimited subsidiaries — perfect for owner-operators with multiple locations, franchises, or asset-protection silos who don't want partnership complexity.

Best fit
Multi-location S-corp ownersFranchiseesAsset-protection-focused operators
Estimated impact
$5K–$20K/yr compliance savings + liability siloing

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