Corporate tax – itx 628, Taxation

Assignment Help:

Problems for Benchmark HW: There are issues here that were not covered in live lecture, but here are some issues that you need to be conscious of when attempting the problems.

t    Deficit in CEP may create and issue of netting between AEP & CEP

t    Property Issues: Sale of assets may cause an increase in the current years E&P

1A)

ISH AB = $40

ISH % ownership = 50%

CSH AB = $100

CSH % ownership = 50%

On April 2, 2010 (one-fourth of the way through the year), D Corp makes a distribution of $100 to Shareholders. A $100 distribution is declared on 12/1/2010, payable on 12/31/2010 to SHs of record on 12/15/2010.  D Corp mails a $100 check to CSH and a $100 check to ISH on 12/31/2010.  The checks are received by CSH and ISH on 1/3/2011. Reg. § 1.451-2(b), Reg. § 1.301-1, Rev. Rul. 64-290, Rev. Rul. 62-131.

When do the SHs have income? On date of 1/3/2011, shareholders will have income. According to Reg. § 1.451-2(b), If payment is made on 12/31/10 does not constitute constructive receipt until the payment is received which was 1/3/2011.

When Does D Corp. Reduce its E & P? On date of April 2, 2010 and 1/3/2011. Section 1.561-2 states that a dividend will be considered as paid when it is received by the shareholder. A deduction for dividends paid during the taxable year will not be permitted unless the shareholder receives the dividend during the taxable year for which the deduction is claimed.

1B)

ISH AB = $40

ISH % ownership = 50%

CSH AB = $100

CSH % ownership = 50%

CEP= $100

AEP = ($100) (this is a deficit)

Dates of Distributions:

4/1/10, 12/1/10

On April 2, 2010 (one-fourth of the way through the year), D Corp makes a distribution of $100 to Shareholders. A $100 distribution is declared on 12/1/2010, payable on 12/31/2010 to SHs of record on 12/15/2010.  D Corp mails a $100 check to CSH and a $100 check to ISH on 12/31/2010.  The checks are received by CSH and ISH on 1/3/2011.

Now Suppose: D Corp has 2010 current E&P of $100 and an accumulated deficit of $100 in its E&P account as of 12/31/2010. Is the distribution declared on 12/1 and payable on 12/31/10 a dividend to the SHs or is the CEP offset by the deficit AEP yielding a return of capital for '11? Calculate the allocation of distributions.

If the current E&P is positive and the AEP is negative, the CEP does not offset the AEP and the distributions will be considered a taxable dividend up to the amount of the CEP.

D Corporation

CE&P  $100

Accumulated deficit   ($100)

1826_Corporate Tax – ITX 628.png

=$200

See: Rev. Rul. 74-164. & Rev. Rul. 65-23

1C)

ISH AB = $40

ISH % ownership = 50%

CSH AB = $100

CSH % ownership = 50%

CEP= $0

AEP = 100

Dates of Distributions:

4/1/10, 12/1/10

On April 2, 2010 (one-fourth of the way through the year), D Corp makes a distribution of $100 to Shareholders. A $100 distribution is declared on 12/1/2010, payable on 12/31/2010 to SHs of record on 12/15/2010.  D Corp mails a $100 check to CSH and a $100 check to ISH on 12/31/2010.  The checks are received by CSH and ISH on 1/3/2011.

Now suppose: suppose D Corp's Acc' E&P as of 12/31/2010 was $100 and its current E&P in 2006 is $0. ? Calculate the allocation of distributions.

1D)

ISH AB = $40

ISH % ownership = 50%

CSH AB = $100

CSH % ownership = 50%

CEP= $(120) deficit

AEP = 100

Dates of Distributions: 4/1/10, 12/1/10

On April 2, 2010 (one-fourth of the way through the year), D Corp makes a distribution of $100 to Shareholders. A $100 distribution is declared on 12/1/2010, payable on 12/31/2010 to SHs of record on 12/15/2010.  D Corp mails a $100 check to CSH and a $100 check to ISH on 12/31/2010.  The checks are received by CSH and ISH on 1/3/2011.


Related Discussions:- Corporate tax – itx 628

1040 Project in Tax Individuals US, Hi Dear, Could you please do my Proj...

Hi Dear, Could you please do my Project in Tax individuals class ..!! and I attached the all Instructions. Thank you

Calculate the amount of fiduciary income, should be on 2012 forms and done ...

should be on 2012 forms and done in pencil. It should include a schedule that shows the fiduciary income calculation and other relevant calculations. Jack Green established the Jac

What are the tax status of the property, Miguel receives tangible personal ...

Miguel receives tangible personal property as an inheritance in 2011. The property was depreciated by the deceased (Miguel's father), and Miguel will also depreciate it. At the dat

Deferred tax asset, Deferred tax asset; taxable income given; valuation all...

Deferred tax asset; taxable income given; valuation allowance. At the end of 2012, Payne Industries had a deferred tax asset account with a balance of $30 million attributable to a

What is the standard deviation of return, A client of Investment Advisor As...

A client of Investment Advisor Associates (IAA), Gillian Bissett, has recently won $5 million in the lottery and has asked for investment advice. She has indicated that she would l

Tds, Dawn's new car has a FMV of $20,000 and it weighs 3,000 pounds. The co...

Dawn's new car has a FMV of $20,000 and it weighs 3,000 pounds. The county also assessed a property tax on the car. The tax was 2% of its FMV and $10 per hundred weight. The car is

Tax memo research , can you help with tax research assignment

can you help with tax research assignment

Write Your Message!

Captcha
Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd