I. Introduction.

Chapter 63, § 32D of the General Laws was amended by St. 2003, c. 4, § 18, effective March 5, 2003. The legislation subjects most qualified subchapter S subsidiaries ("QSUBs"), as defined under I.R.C. § 1361, to the entity level tax on net income under G.L. c. 63, § 32D(a)(ii) of the corporate excise. To be subject to the tax, a QSUB must have total receipts for the taxable year of $6 million or more, computed by taking into account the rules for aggregating those receipts set out in section II of this TIR. The rates of tax under c. 63, § 32D(a)(ii) are 3% of net income for total receipts of $6 million to $9 million and 4.5% of net income for total receipts of $9 million or more. Additionally, under § 32D(a)(i), the new legislation subjects every QSUB that receives income that would have been taxed to it for federal income tax purposes had it been treated federally as a separate S corporation ( e.g., certain built-in gains and passive investment income, I.R.C. §§ 1374 and1375) to a separate entity level tax on such income at the 9.5% rate specified in G.L. c. 63, § 32(a)(2) or § 39(a)(2).

Prior to the new legislation, a QSUB was not subject to the tax on net income under G.L. c. 63, § 32D or to the net income measure of the corporate excise under G.L. c. 63, § 32(a)(2) or § 39(a)(2). Rather, all of the QSUB's items of income, loss, deduction, and credit were treated as though earned by and taxed to its parent. LR 99-17. A QSUB was subject to the corporate excise only in an amount equal to the greater of (i) the non-income measure imposed under G.L. c. 63, § 32(a)(1) or § 39(a)(1), or (ii) the minimum tax imposed under G.L. c. 63, § 32(b) or § 39(b), currently $456. Id. The new legislation did not eliminate this liability; QSUBs continue to remain liable for these excises, as applicable.



Under the new legislation, a QSUB's Massachusetts S corporation parent also must determine the net income measure of the corporate excise differently from how it determined it under prior law, as discussed in sections IV. and V.B, below. However, its non-income measure of the excise remains the same. In addition, its items of income, loss, deduction and credit, together with those of its QSUBs will continue to flow through to its shareholders and be taxed under G.L. c. 62, § 17A.

Finally, determining the tax liability of QSUB parents that are not taxable as Massachusetts S corporations is unaffected by the new legislation. Accordingly, a QSUB parent that is a corporate trust, financial institution, or partnership, etc., for Massachusetts tax purposes, although an S corporation for federal income tax purposes, will continue to take into account its QSUBs' income, loss, deduction, and credit in determining its net income subject to tax under G.L. c. 62 or c. 63, as applicable. See I.R.C. § 1361(b)(3). See also LR 99-17.

This Technical Information Release ("TIR") explains the filing requirements for a QSUB and its Massachusetts S corporation or non-S corporation parent and how each must determine its Massachusetts tax liability as a result of the 2003 amendments to G.L. c. 63, § 32D.

II. Computing Total Receipts under G.L. c. 63, § 32D(a)(ii) of the Corporate Excise.

A. Total Receipts Must be Aggregated.

For purposes of determining whether, and at what rate, a QSUB that is not taxed as a financial institution[ 1] is subject to the entity level tax on net income under G.L. c. 63, § 32D(a)(ii) for taxable years beginning with the year in which March 5, 2003 falls, the QSUB's total receipts, as defined in G.L. c. 63, § 32D and 830 CMR 62.17A.1(2), are to be computed by combining them with those of its parent, whether a Massachusetts S corporation, corporate trust, or partnership, etc., but not a financial institution, and any other related[ 2] S corporation, QSUB, or entity with which it is engaged in a unitary business as required by 830 CMR 62.17A.1(11)(e) and (f). The aggregated total receipts of all such entities may be adjusted to avoid double counting but must include income taxable at the entity level under G.L. c. 63, § 32D(a)(i). However, such income is not includable in the QSUB's net income subject to tax under G.L. c. 63, § 32D(a)(ii). If the combined total receipts are at least $6 million but less than $9 million, a tax is imposed on the separately determined net income of the QSUB at a 3% rate. A 3% tax also is imposed on the separately determined net income of any other QSUB or S corporation otherwise taxable under the corporate excise that aggregated its receipts with the QSUB. If total receipts are $9 million or more a tax is imposed on the separately determined net income of the QSUB at a 4.5% rate. A 4.5% tax also is imposed on the separately determined net income of any other QSUB or S corporation otherwise taxable under the corporate excise that aggregated its receipts with the QSUB.

B. Computing Total Receipts for the Taxable Year in Which March 5, 2003 Falls and Thereafter.

For the taxable year in which March 5, 2003 falls and thereafter, each entity required to aggregate total receipts under section II.A. above, must first compute its total receipts separately for the entire taxable year before aggregating. Accordingly, in computing a QSUB's total receipts for the taxable year in which March 5, 2003 falls, a QSUB must include in its calculation all of its receipts for the entire year, without regard to the March 5, 2003 date. Additionally, in computing the QSUB's parent's total receipts for the taxable year in which March 5, 2003 falls, to avoid double counting, the parent should not include in its calculation the receipts attributable to its QSUBs. In computing an entity's total receipts for a taxable year consisting of fewer than twelve months, however, the annualization rule at 830 CMR 62.17A.1(11)(c) will apply.

Example 1: Computing and Aggregating Total Receipts of a Massachusetts S Corporation Parent With One QSUB

Assume a calendar year QSUB and a calendar year Massachusetts S corporation parent. Assume that the QSUB has total receipts of $5,000,000 prior to March 5, 2003 and $2,000,000 for the remainder of the calendar year. Assume that the parent has total receipts, independently of the QSUB, of $3,000,000 for the calendar year.

For purposes of determining whether and at what rate the S corporation parent and its QSUB are subject to taxation under G.L. c. 63, § 32D(a)(ii) for calendar year 2003, their aggregated total receipts for the year are calculated as follows. First the total receipts of the QSUB for the taxable year beginning January 1, 2003 and ending December 31, 2003 are calculated by disregarding the March 5, 2003 date and adding together $5,000,000 and $2,000,000 to equal $7,000,000. Second, the S corporation parent's total receipts of $3,000,000 for calendar year 2003 are aggregated together with those of the QSUB to equal $10,000,000. Since the aggregated total receipts are over $9,000,000, under § 32D(a)(ii), a tax will be imposed on the separately determined net income of each entity at a 4.5% rate. In computing the QSUB's net income, see section III., below. In computing the S corporation parent's net income, see section IV., below. In addition, the S corporation parent's items of income, loss, deduction, and credit, together with those of its QSUB, will continue to flow through to its shareholders on the Schedule SK-1, Shareholder's Massachusetts Information, and be taxed under G.L. c. 62, § 17A at the 5.3% rate.

Example 2: Computing and Aggregating Total Receipts of a Corporate Trust Parent With One QSUB

Assume a calendar year QSUB and a calendar year corporate trust parent. Assume that the QSUB has total receipts of $2,000,000 prior to March 5, 2003 and $3,000,000 for the remainder of the calendar year. Assume that the parent has total receipts, independently of the QSUB, of $2,000,000 for the calendar year.

For purposes of determining whether and at what rate the QSUB is subject to taxation under G.L. c. 63, § 32D(a)(ii) for calendar year 2003, the aggregated total receipts of the QSUB and its corporate trust parent are calculated as follows. First the total receipts of the QSUB for the taxable year beginning January 1, 2003 and ending December 31, 2003 are calculated by disregarding the March 5, 2003 date and adding together $2,000,000 and $3,000,000 to equal $5,000,000. Second, the corporate trust parent's total receipts of $2,000,000 for calendar year 2003 are aggregated together with those of the QSUB to equal $7,000,000. Since the aggregated total receipts are over $6,000,000 but less than $9,000,000, under § 32D(a)(ii), a tax will be imposed on the separately determined net income of the QSUB at the 3% rate. See section III., below. The corporate trust parent is not subject to tax under G.L. c. 63, § 32D(a)(ii). However, its items of income, loss, deduction and credit, will continue to be taxed, together with those of its QSUB, on Form 3F, Income Tax Return of Corporate Trust, under G.L. c. 62, § 8(a) at the 5.3% rate.

III. Computing a QSUB's Net Income Subject to Tax under the Corporate Excise for the Taxable Year in Which March 5 Falls and Thereafter.

In determining a QSUB's net income subject to tax under G.L. c. 63, § 32D(a)(i) and (ii) of the corporate excise for the taxable year in which March 5, 2003 falls, only net income from the period beginning March 5, 2003, and ending on the last day of the QSUB's taxable year need be considered. Alternatively, for record keeping ease and convenience, net income may be calculated beginning March 1, 2003 and ending on the last day of the QSUB's taxable year, if the QSUB so elects. A QSUB may compute its net income for such period on a pro rata basis by dividing its total net income for the taxable year by 365 and then multiplying the resulting figure by the number of days in the period. The foregoing rule assumes the QSUB's taxable year consists of twelve months. If the QSUB's taxable year consists of less than twelve months, the 365 figure must be adjusted accordingly. Alternatively, an actual accounting of the QSUB's net income for the period may be made. Depending on the accounting method used, expenses must be accounted for in the same manner. The method used must be clearly noted on the QSUB's tax return. For taxable years beginning after March 5, 2003 the QSUB must determine its net income for purposes of § 32D(a)(i) and (ii) based on its own items of income, loss, deduction and credit for the taxable year.

IV. Computing a Massachusetts S Corporation Parent's Net Income Subject to Tax under the Corporate Excise for the Taxable Year in which March 5 falls and Thereafter.

If the net income measure of the corporate excise under G.L. c. 63, § 32D(a)(i) or (ii) applies to a QSUB's Massachusetts S corporation parent for the taxable year in which March 5, 2003 falls, using the method of accounting consistent with that of its QSUB under section III, above, the Massachusetts S corporation parent must take all of its QSUB's items of income, loss, deduction, and credit into account in determining its net income only through March 4, 2003 (or through the end of February, if the QSUB has so elected). From March 5, 2003 (or March 1, 2003, if applicable) until the end of its taxable year, as well as for all taxable years thereafter, however, the Massachusetts S corporation parent must determine its net income for purposes of § 32D(a)(i) and (ii) based solely on its own items of income, loss, deduction, and credit.



V. Apportioning Income under the Corporate Excise.

A. QSUBs.

For the taxable year in which March 5, 2003 falls, a QSUB must use its property, payroll, and sales only for the period beginning March 5 or 1, whichever is applicable, and ending at the end of its taxable year in determining its apportionment percentage for purposes of calculating the net income measure of the corporate excise imposed under G.L. c. 63, § 32D(a)(i) or (ii). For taxable years thereafter, a QSUB's apportionment percentage is based on its own separately determined property, payroll, and sales for the taxable year.

B. Massachusetts S Corporation Parents.

A Massachusetts S corporation parent must include its QSUBs' property, payroll, and sales in determining its apportionment factors only through March 4, 2003 (or through the end of February, if an election as noted in section III. above, is made by its QSUBs). From March 5, 2003 (or March 1, 2003, if applicable) until the end of its taxable year, as well as for all taxable years thereafter, however, the Massachusetts S corporation parent must determine its apportionment factors based solely on its own property, payroll, and sales.

VI. What Has Not Changed in Computing a Massachusetts S Corporation Parent's Tax Liability as a Result of the New Legislation.

Unlike the impact the new legislation has had on how a QSUB's Massachusetts S corporation parent is taxed under the income measure of the corporate excise, as discussed in sections IV. and V.B, above, what has not changed for such S corporation parent as a result of the new legislation is as follows:

  1. a Massachusetts S corporation parent's items of income, loss, deduction, and credit, together with those of its QSUBs, will continue to pass through and be taxable to its shareholders to the extent such pass through is required under G.L. c. 62, § 17A and 830 CMR 62.17A.1(5)-(7);
  2. for purposes of determining a non-resident shareholder's distributive share of income, loss, deduction, and credit taxable in Massachusetts under G.L. c. 62, § 17A and 830 CMR 62.17A.1(6), a QSUB's Massachusetts S corporation parent will continue to determine its apportionment factors by including its QSUBs' property, payroll, and sales;
  3. for purposes of determining whether, and at what rate, a QSUB's Massachusetts S corporation parent is subject to the net income measure of the corporate excise under G.L. c. 63, § 32D(a)(ii) , the Massachusetts S corporation parent will continue to aggregate its total receipts with those of its QSUBs and other related S corporations and other entities with which it is engaged in a unitary business, as provided in section II., above; and
  4. for purposes of determining the non-income measure of the corporate excise for taxable years beginning with the year in which March 5, 2003 falls, the Massachusetts S corporation parent will continue to determine and report its taxable tangible property or taxable net worth based solely on its own assets and liabilities.
    See TIR 97-6.

Vll. Tax Returns.

A. QSUBs.

Prior to March 5, 2003, every QSUB doing business in Massachusetts was taxable at the entity level on taxable tangible property or taxable net worth and was required to file Form 355S, S Corporation Excise Return, to report the non-income measure or the minimum corporate excise. TIR 97-6. This requirement continues. Effective March 5, 2003, every QSUB also must report on Form 355S, the net income measure of the corporate excise under G.L. c. 63, § 32D(a)(i) and § 32(a)(2) or § 39(a)(2), as applicable. See section III., above. Additionally, every QSUB with total receipts for the taxable year of $ 6 million or more (determined by aggregating total receipts as set out in section lI., above) also must report thereon the net income measure of the corporate excise under G.L. c. 63, § 32D(a)(ii). Id. Despite these midyear-reporting changes, only one return will be required to be filed, not two short year returns.

Pro-Forma Form 1120 Required. Every QSUB subject to a tax at the entity level under the income measure of the corporate excise as a result of the new legislation must attach to its Form 355S filed for the taxable year in which March 5, 2003 falls a pro-forma Form 1120, U.S. Corporation Income Tax Return, and any other form or schedule that provides information about the QSUB's own, separately determined, income, loss, deduction, and credit for the entire taxable year. Such forms and schedules must be attached to Forms 355S filed in subsequent tax years as well.

B. Massachusetts S Corporation Parents.

Prior to March 5, 2003, every Massachusetts S corporation parent with a QSUB was required to file Form 355S and include thereon its items of income, loss, deduction, and credit, together with those of its QSUB, in determining net income subject to tax under G.L. c. 63, § 32D and § 32(a)(2) or § 39(a)(2). For purposes of determining the non-income measure of the corporate excise, the Massachusetts S corporation parent determined and reported its taxable tangible property or taxable net worth on Form 355S based solely on its own assets and liabilities. In addition, the Massachusetts S corporation parent was required to report on a Schedule S-K1, Shareholder's Massachusetts Information, the distributive share income, including the income of the QSUB, of each of its shareholders. TIR 97-6.

For the taxable years beginning with the year in which March 5 falls, a Massachusetts S corporation with a QSUB must continue to file Form 355S and report its taxable tangible property or taxable net worth for purposes of the non-income measure of the corporate excise. It must also continue to report on a Schedule SK-1 the distributive share income, including the income of the QSUB, of each of its shareholders.

For purposes of the income measure of the corporate excise under G.L. c. 63, § 32(a)(2), § 39(a)(2), and § 32D(i) and (ii), for the taxable year in which March 5, 2003 falls, the Massachusetts S corporation parent will only include the income of its QSUB through March 4. For the period beginning March 5, the Massachusetts S corporation parent will no longer include on its Form 355S its QSUB's income. Despite this midyear reporting change, only one return will be required to be filed, not two short year returns. In subsequent tax years, the Massachusetts S corporation will continue to include only its own income on the Form 355S for purposes of the income measure of the corporate excise.

C. Non-S Corporation Parents.

Determining the tax liability of all non-S corporation QSUB parents is unaffected by the new legislation. Accordingly, a QSUB parent that is a corporate trust, financial institution, or partnership, etc., for Massachusetts tax purposes, although an S corporation for federal income tax purposes, will continue to take into account, its QSUB's income, loss, deduction, and credit in determining its net income subject to tax under G.L. c. 62 or c. 63, as applicable, before and after March 5, 2003. See I.R.C. § 1361(b)(3). See also LR 99-17. Thus, a corporate trust parent, for example, will continue to file for taxable years beginning with the year in which March 5, 2003 falls a Form 3F and report thereon not only its own income but income attributable to its QSUBs even though beginning March 5, 2003 those QSUBs also may be liable for tax on their income on Form 355S . Similarly, a financial institution parent will continue to file a Form FI and report its own income together with that of its QSUBs. However, unlike the QSUBs of the corporate trust, its QSUBs will continue to file Form FI and pay the minimum financial institution excise. See section X, below.

D. Filing Due Date.

Generally, the Form 355S, together with payment in full of any tax due, must be filed by a QSUB and its Massachusetts S corporation parent on or before the fifteenth day of the third month after the close of the taxable year.

E. Combined Returns of Income Not Allowed.

In the event that a QSUB has more than one related QSUB or other S corporation subject to the income measure of the corporate excise, a separate Form 355S must be filed for each QSUB and S corporation. A Form 355C, Combined Business or Manufacturing Corporation Excise Return, cannot be filed in such a case as the combined QSUB/S corporation group is not eligible to elect to file a combined return under G.L. c. 63, § 32B and 830 CMR 63.32B.1, entitled Combined Returns of Income. Under § 32B and the regulation, a prerequisite to filing a combined return is that the combined group filed a consolidated return with the federal government in the taxable year for which the election is made, a requirement that cannot be met as S corporations are not eligible to file a federal consolidated return. I.R.C. § 1504(b)(8).

VIII. Estimated Taxes.

A. QSUBs.

Every QSUB that can reasonably estimate its corporate excise to be in excess of $1,000 for the taxable year in which March 5, 2003 falls, and for any taxable year thereafter, must make estimated tax payments to the Commonwealth. Estimated tax payments are to be calculated according to the provisions of G.L. c. 63B and 830 CMR 63B.2.2. Also, the safe harbor provisions in G.L. c. 63B, § 3(c) and 830 CMR 63B2.2(8)(b) that excuse the underpayment penalty apply, with one modification which follows. For purposes of the taxable year in which March 5, 2003 falls, but not for subsequent taxable years, the exclusion of large corporations from the safe harbor provision in G.L. c. 63B, § 3 (c)(ii) does not apply. Accordingly, the "100% of the preceding taxable year" safe harbor, G.L. c. 63B, § 3(c)(ii), will be available in determining whether an underpayment penalty is owed by a QSUB that is a large corporation for the taxable year in which March 5, 2003 falls, but not in any subsequent taxable year in which the QSUB qualifies as a large corporation.[ 3]

In determining the underpayment penalty of a QSUB, the provisions of the public announcement issued by the Commissioner of Revenue on March 3, 2003, originally applicable only to QSUBs filing returns on a calendar year basis, are extended to all QSUBs. Accordingly, the first of four installment payments due, whether due on March 17, 2003 or on some other date, is not required. Additionally, there will be no underpayment penalty imposed upon any QSUB that fails to make a first installment payment . The remaining three installment payments will be required to be paid as follows. The first installment will be due on or before June 16, 2003, if a calendar year QSUB, or on or before some other applicable date, depending upon the fiscal year of the QSUB, and should equal 65% of the QSUB's required annual payment. The second installment is due either on or before September 15, 2003 or some other applicable date, and should be equal to 25% of the QSUB's required annual payment. The third and final installment is due either on or before December 15, 2003 or some other applicable date, and should be equal to 10% of the QSUB's required annual payment. In determining the underpayment penalty with respect to any of these three installment payments, no underpayment penalty will be imposed upon any QSUB for any installment payment that may become due prior to the issuance of this TIR.



B. Massachusetts S Corporation Parents.

Each QSUB parent that is a Massachusetts S corporation that can reasonably estimate its corporate excise to be in excess of $1,000 for the taxable year in which March 5, 2003 falls, also must make estimated tax payments to the Commonwealth, generally as spelled out in section VIII.A., above. However, in determining a Massachusetts S corporation parent's corporate excise liability for such year, it must do so based not only on its own items of income, loss, deduction, and credit for the entire year, but on items of income, loss, deduction and credit of its QSUBs through March 4, 2003 (or through the end of February, if an election as noted in section III., above is made by its QSUBs).

In determining a Massachusetts S corporation parent's corporate excise liability for taxable years thereafter, however, such S corporation parent must do so based solely on its own items of income, loss, deduction, and credit. Items of income, loss, deduction and credit of its QSUBs should not be included. In determining the underpayment penalty of a Massachusetts S corporation parent, the first of its four installments due is not required. Additionally, there will be no underpayment penalty imposed upon any such S corporation that fails to make a first installment payment or any other installment payment that may become due prior to the issuance of this TIR.

C. Non-S Corporation Parents.

A non-S corporation parent, such as a corporate trust, financial institution, or partnership, etc, should continue to determine its income tax or financial institution excise liability for the taxable year in which March 5, 2003 falls, and for any taxable year thereafter, and should continue to calculate its estimated tax payments for such years as it has always done according to the provisions of G.L. c. 62B, § 14 or G.L. c. 63B and 830 CMR 63B.2.2, as applicable. Calculating the estimated tax payments of a non-S corporation parent is unaffected by St. 2003, c. 4, § 18.

  1. Misapplied Estimated Tax Payments.

It has come to the Department's attention that pursuant to the new legislation some estimated tax payments may have been incorrectly applied to the accounts of QSUBs that should have been applied to their parents. Taxpayers may follow the procedures set out in TIR 01-3 to request that the payments be reallocated to the proper accounts.

IX. Installment Sales.



Income received by a QSUB on or after March 5, 2003 attributable to an installment sale it entered into before March 5, 2003 must be included in computing its income subject to tax on or after March 5, 2003, assuming that an election to report such income on the installment method has been approved by the Commissioner of Revenue. See AP 201.1.

X. QSUBs and the Financial Institution Excise.

A QSUB parent that is an S corporation is taxed as a financial institution if it falls within the definition of financial institution in G.L. c. 63, § 1. TIR 00-6, part IV.C. For purposes of clause (e) of the statutory definition of "financial institution" in § 1, the gross income of the S corporation parent and the QSUB is combined so that if more than 50% of the combined income, excluding non-recurring extraordinary items, is derived from loan origination, lending activities (including discounting obligations), or credit card activities, the S corporation parent will be subject to tax as a financial institution. Id.

If a QSUB's S corporation parent meets the 50% test under clause (e) so that it is subject to tax as a financial institution under G.L. c. 63, § 2, it must file Form 63FI, Massachusetts Financial Institution Excise Tax Return. TIR 00-6, part IV.C. In determining its net income subject to tax under § 2, such parent must take into account its QSUBs' income, loss, deduction, and credit.[ 4] In such a case, as separate taxpayers, any of its QSUBs that are taxable in Massachusetts must file Form 63FI as well and pay the minimum excise imposed upon financial institutions under G.L. c. 63, § 2(a). Id. Since the S corporation parent and any QSUBs subject to tax here are taxed under the financial institution excise under G.L. c. 63, §§ 1, 2, they are not subject to the non-income measure of the corporate excise imposed under G.L. c. 63, § 32(a)(1) or § 39(a)(1) or the minimum corporate excise under G.L. c. 63, § 32(b) or § 39(b). Therefore, they are not subject to tax under c. 63, § 32D, which by its terms reaches only domestic or foreign S corporations or QSUBs that are taxable under § 32 or 39 of the corporate excise. G.L. c. 63, § 32D(a).

Conversely, any QSUB that is not subject to the financial institution excise under G.L. c. 63, § 2 because its parent is a corporate trust or some other unincorporated entity that falls outside the definition of financial institution, or because the 50% test of G.L. c. 63, § 1, clause (e) is not met, is subject to taxation under G.L. c. 63, § 32D, if applicable, because this QSUB is subject to the non-income measure of the corporate excise imposed under G.L. c. 63, § 32(a)(1) or § 39(a)(1), or the minimum corporate excise imposed under G.L. c. 63, § 32(b) or § 39(b). See LR 01-9; TIR 00-6; and DOR-D 00-9; and G.L. c. 63, § 32D(a). As stated above, § 32D(a) specifically states that QSUBs subject to an excise under § 32 or § 39 of c. 63 are subject to taxation under § 32D.

/s/Alan LeBovidge
Alan LeBovidge
Commissioner of Revenue

AL:LEM:ps

ENDNOTES:
1. See section X, below.[ return to text]
2. A QSUB and another S corporation or QSUB are "related" if "common stock ownership" exists between them as explained at 830 CMR 62.17A.1(11)(e). Similarly, a QSUB and another entity are "related" if "common ownership" exists between them as explained at 830 CMR 62.17A.1(11)(f). [ return to text]
3. The "100% of the preceding taxable year exception," as well as every other exception in G.L. c. 63B, § 3(c), are figured on Form M-2220, Underpayment of Massachusetts Estimated Tax by Corporations. [ return to text]
4. In addition, the S corporation must report on a Schedule S-K1, Shareholder's Massachusetts Information, the distributive share income, including the income of any QSUB, of each of its shareholders. G.L. c. 62, § 17A and TIR 00-6, part IV.B. [ return to text]
161876/35664

September 25, 2003

TIR 03-20