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

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

Ch. 6 #62, Roberta Santos, age 41, is single and lives at 120 Sanborne Aven...

Roberta Santos, age 41, is single and lives at 120 Sanborne Avenue, Springfield, IL 60781. Her Social Security number is 123-45-6789. Roberta has been divorced from her former husb

Tax file, Carol is a successful physician who owns 100% of her incorporated...

Carol is a successful physician who owns 100% of her incorporated medical practice. She and her husband, Jared, are considering the purchase of a commercial office building located

I have no ideal how to figure this out, Scenario: The Park family consists...

Scenario: The Park family consists of the following: •Jackie O. Park; age 40; DOB: 3/23/1970; SSN: 123-45-6789; business analyst; single; unmarried •Leslie T. Park; age 16; DOB:

Real Estate Taxation - 1031 Like-Kind Exchange, The taxpayer exchanges prop...

The taxpayer exchanges property in 2010 with a fair market value of $5,500,000 that has a basis of $750,000. The property is also subject to a mortgage of $2,500,000. The taxpaye

Taxation - opportunity cost of capital and tax rate given, BBQ Beach corpor...

BBQ Beach corporation manufactures inflatable air-matresses and life jackets for summer fun. the firm is considering replacement of their existing production line (CCA Class 8, d=2

Importance of creating a surplus budget, a) Using the above information you...

a) Using the above information you are to construct Fiona's Cash Flow Statement and then explain to her the importance of creating a surplus budget. b) The Net Worth Statement e

Determine tax expense, Given the below information, provide the journal ent...

Given the below information, provide the journal entry to recognize tax expense. Assume taxes are paid immediately (with cash). Note: the statutory rate is assumed to be 40%. As

Accounting for income taxes, Gustav Ltd commenced operations on 1 July 2011...

Gustav Ltd commenced operations on 1 July 2011 and presents its first statement of comprehensive income for the year ending 30 June 2012 and first statement of financial position a

Tax court, 1. Although she left her job in November of Year 1, Patrice was ...

1. Although she left her job in November of Year 1, Patrice was entitled to a year-end bonus. On December 30, her former boss called her to let her know the check was available. Pa

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