The formulas
- Income test: personal holding company income / adjusted ordinary gross income >= 60%
- Stock test: more than 50% in value owned by not more than 5 individuals in the last half of the year
- Tax = 20% x undistributed personal holding company income
How it works
A corporation is a personal holding company if it meets both tests in section 542(a): at least 60 percent of adjusted ordinary gross income is personal holding company income, and more than half the stock value is owned by five or fewer individuals at some time in the last half of the year. Corporations in the exceptions of section 542(c) are outside the definition.
The tax is 20 percent of undistributed personal holding company income, which is taxable income with the adjustments in section 545 less the dividends paid deduction. Enter that figure from your own section 545 computation, because this tool does not rebuild it. Rules that attribute stock ownership to individuals through entities are not modeled.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
Which income counts as personal holding company income?
Section 542 refers to the definition in section 543. Use that section to classify your income.
What is the tax base?
Undistributed personal holding company income as defined in section 545. Enter your own computation.
What is the rate?
Section 541 sets 20 percent.
Sources
- 26 U.S.C. 541, Imposition of personal holding company tax, Legal Information Institute
- 26 U.S.C. 542, Definition of personal holding company, Legal Information Institute
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