One operational challenge that S-corporations face is the challenge of converting from a C-corporation into an S-Corporation. We've studied the concept of corporate earnings and profits in some detail this term. If you think about it, earnings and profits and their associated tax consequences do not disappear because a corporation changes from a C-corporate form to an S-Corporate form. Rather those C-corporate earnings are tracked for decades and if they are ever distributed they are subjected to double taxation. Given that structure and the relative ease of completing a type F reorganization, should a C-corporation evet elect to become a S-corporation or is there a better way?