Chapter 3 Flashcards
tax costs are _______ when tax rates are high and ______ when tax rates are lower
higher; lower
two basic timing strategies when tax rates are constant
- defer recognizing taxable income to future period
- accelerate deductions to current period
2 limitations to timing
- inability to defer income/deductions
- a cash basis taxpayer must recognize income for taxes when it is actually or constructively received
3 tests for constructively received
- amount is known or estimable
- taxpayer is legally entitled to amount
- taxpayer controls the timing of receipt
income shifting
taxes advantage of varying tax rates across taxpayers and taxing jurisdictions
related parties
shifting from a high taxed relative to a lower taxed relative (ex: parent to child)
Business Purpose doctrine
allows the IRS to challenge and disallow business expenses for transactions with no underlying business motivation
Step-Transaction Doctrine
allows the IRS to collapse a series of related transactions into one transaction to determine tax consequences
Economic Substance Doctrine
a transaction must change taxpayer’s economic position and have substantial purpose in order to receive tax benefits
tax avoidance
legally arranging your affairs to pay the minimum amount of tax
tax evasion
illegally avoiding tax on income or taking deductions that are not authorized
tax gap
difference between taxes owed and taxes collected