Subject to a few exceptions, a corporation that has elected to be taxed under subchapter S of chapter 1 of subtitle A of title 26 of the United States tax code is not taxed on its net income. Instead, the income, deductions, credits, and other tax items of an S corporation pass through to its shareholders on a pro rata basis. To qualify for subchapter S treatment, an electing corporation must satisfy the requirements that are set forth in section 1361, one of which is that the corporation can have no more than 100 shareholders. One aspect of that requirement is the focus of this article.
Kahn, Douglas A. "All in the Family as a Single Shareholder of an S Corporation." J. H. Kahn and T. G. Perris, co-authors. Tax Notes 116 (2007): 791-4.