Loan to 5% Owner in S-Corp.

[Guest]

I have a case of an S-corp owner who just told us that he switched to an S from a C-Corp several years ago. This is in spite of the fact that we ask each year in our census! Anyway, he has a loan that he will pay off immediately. Can this be corrected through APRSC by repayment, deeming the distribution in the year the conversion was made and amending the owner's tax return for that year? Alternatively, must this corrected through VCR? Thanks.

[QDROphile]

You may have a disqualification event that can be remedied, but you also have a prohibited transaction. Prohibited transactions are not handled in VCR.