Corporate Flashcards
AMT Exemption
$40,000 - (25% * Excess AMT over $150,000)
Shareholder Gain on Formation
Realized gain = FMV property contributed - Basis
Recognized gain = Lesser of realized & Boot received (No gain if no boot)
If debt attached to property is higher than basis, Recognize to extent liability exceeds basis
Maximum income subject to Accumulated Earnings Credit
Taxable Income - Federal Income Taxes - $250,000 Accumulated Earnings Credit
NOL
Carried back 2 forward 20 years
- DRD included in calculation of NOL
Shareholder Basis in Dividend
FMV Property Received
Shareholder Reorganization
Gain = 0 or boot received
Liquidation of Sub
0 Gain recognized by parent
Charitable Contribution
(Revenues - Expenses + Dividends) * 10%
Taxable Income calculated absent deduction for charitable contribution, dividends received, net operating loss, and capital loss
Taxable Income
Section 351 transfer
Gain recognized = 0 if after transfer taxpayer or taxpayers own 80% or more of corporation’s stock, solely in exchange for stock
Corporation Basis in Property
Shareholder’s Basis + Shareholder Gain Recognized
Liquidation
Sell Assets & Distribute Cash
Corporation: Gain = Sale Price - Basis
Shareholder: Gain = Cash Proceeds - Stock Basis
Distributes Assets
Corporation: Gain = FMV - Adjusted Basis
Shareholder: Gain = Sale Price property recieved - Stock Basis
Organizational Costs
(Organizational Costs - $5,000) / 180 Months * Months in year
Shareholder Basis in Stock
Basis of Property Transferred
+ Gain Recognized
- Boot Received
- Liabilities Assumed by Corporation
Corporate Gain on Distribution
FMV - Basis
Shareholder Gain on Distribution
Current E&P + Gain = Taxable Dividend
Accumulated E&P = Taxable Dividend
Return of Capital (No E&P) = Tax free reduction of basis
No E&P or basis = Taxable income as capital gain