Hawaiian Memories Case Study

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Hawaiian Memories, Inc. (HMI) was founded in 2007 in Maui, HI by Angie Lee and Bob Lin. HMI is markets specialty tourism products of the Islands of Hawaii. HMI is a C-corporation with the following shares:
200 shares of Preferred stock and 2,000 shares of Common voting stock as follows:
• Angie Lee, native Hawaiian, lives in San Francisco, CA since 2012, owns 100 shares of Preferred and 1,000 shares of Common voting stocks.
• Bob Lin, native Hawaiian, lives in Maui, HI, owns 100 shares and of Preferred and 1,000 shares of Common voting stocks.
1,000 shares of Common non-voting stock as follows:
• Plantation Sugar Partnership (PSP) owns 500 shares. Bob Lin and his sister Katie each own 50% of PSP. PSP is an HMI supplier.
• 2 of HMI employees, native …show more content…
Nevertheless, Inge will be relocating back to Sweden in one year. As stated in the 26 US Code §7701(b)(2)(B)(iii) Inge will not be considered as a US resident starting on the first day of the last year before moving to Sweden. According to the IRC § 1361(b)(1)(C) nonresident alien cannot be a shareholder of an S-corporation, which will terminate the S election for HMI.
b. According to the Code of Federal Regulations CFR §301.7701-3(b)(1)(i) the partnership must have at least 2 owners. At the same time, a partnership for State tax purposes could be disregarded as an entity for Federal tax purposes if a Partnership is owed by an individual and, for instance, a single member LLC, owed by the same individual (See IRS Letter Ruling 200439028). PSP does not fall into the category of Disregarded Entity for Federal income tax purposes because it is owed by two individuals.
Stated above violates the requirements for an S election. Therefore, HMI will be taxed on the C Corporation level.
Issue and Conclusion 2
Is HMI eligible for an S election given the facts that it has common (voting and non-voting), and preferred

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