Page 403 - Small Business IRS Training Guides
P. 403
Audit Considerations
As part of the S corporation audit, the examiner should verify that each shareholder is a valid S corporation shareholder,
and for an ESBT shareholder the examiner should verify that all potential current beneficiaries are allowable beneficiaries.
Summary
A nonresident alien shareholder is allowed to be a potential current beneficiary of an Electing Small Business Trust.
73233-102 13541-4 Tax Cuts and Jobs Act