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

Study case of an exam of GST in new zealand, my level Master of the Paper G...

my level Master of the Paper GST ( law) I have an exam case I have already answered I need to revise the high level tutor ( 5000 words) Can you help me?

Compute the service and interest cost for 2012, Sachs Brands' defined benef...

Sachs Brands' defined benefit pension plan specifies annual retirement benefits equal to: 1.2% × current service years × final year's salary, payable at the end of each year. Angel

Computation, "Alfred E. Old and Beulah A. Crane, each age 42, married on Se...

"Alfred E. Old and Beulah A. Crane, each age 42, married on September 7, 2010. Alfred and Beulah will file a joint return for 2011. Alfred''''s Social Security number is 111-11-111

Calculate the tax, Sue, Scarlett and Sally are in a partnership together pr...

Sue, Scarlett and Sally are in a partnership together providing accounting services.  The partnership uses the cash basis to account for income tax.  Under the partnership agreemen

Cgt provisions, In relation to the CGT provisions, which of the following s...

In relation to the CGT provisions, which of the following statements are correct? Explain your answer citing the relevant law. (a) When disposal of property (CGT event A1) is by

INTRODUCTION TO VAT, 31 VAT WAS FIRST INTRODUCED AS A TAX IN WHICH YEA...

31 VAT WAS FIRST INTRODUCED AS A TAX IN WHICH YEAR AND IN WHICH COUNTRY?

Calclution, Ask question #Minimum 100 words Problem 4-42 (LO. 3, 4) Faye, G...

Ask question #Minimum 100 words Problem 4-42 (LO. 3, 4) Faye, Gary, and Heidi each have a one-third interest in the capital and profits of the FGH Partnership. Each partner had a c

Fringe benefits tax, Mr and Mrs Adams and Mr Adam's mother, Louise, bought ...

Mr and Mrs Adams and Mr Adam's mother, Louise, bought an investment property equally as joint owners in 1979 for $30000. Mr Adams died in 2005. Louise died in 2006. The property wa

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

Determine net operating loss carryover, Good Health Company Inc. began busi...

Good Health Company Inc. began business in 2007 and has operating results as listed below. In 2009 & 2010 it generated net operating losses of $75,000 and $120,000 respectively. Th

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