Corporate Taxation Flashcards
Section IRC that covers property transfers to a corporation solely in exchange for stock, and which immediately after the exchange those persons transferring property control (80%) the corporation
Sec. 351
Any domestic corp whose aggregate amount of money and adjusted basis of other property received for stock, as a contribution to capital, and as paid-in surplus, does not exceed $1,000,000
Small business stock
Section of IRC that allows shareholders of Small business stock to deduct an ORDINARY loss on the sale or worthlessness of stock if meet requirements
Section 1244 stock
Tax form that corp’s must file every year, even if have no taxable income
-Must be filed by 15th day of 3rd month following close of its taxable year
Form 1120 ( short form 1120-A if gross receipts, total income, and total ssets each <$500k)
Taxable income computed with specified adjustments and increased by tax preferences
Alternative Minimum Tax
Supplemental schedule that corporations must attach to their Form 1120 that reconciles book income to taxable income
Schedule M-1
Supplemental tax schedule that corp’s must include on their Form 1120 that reconciles beginning to ending retained earnings PER BOOKS
Schedule M-2
Supplemental tax schedule that corps with total assets >$10 M must include with their Form 1120 that is a more detailed version of the M-1
Schedule M-3
Supplementary tax schedule that must be completed and attached to Form 1120 if the corporaiton (1) has total assets of at least $100 M and (2) has taken a tax position on its return and the coproration or a related party has either recorded a reservewith respect taht position or did not record reserve because the corp expects to litigage the position
Schedule UTP (Uncertain tax position)
A parent-subsidiary chain of corporaitons in which at least 80% of the combined voting power and total value of all stock (except nonvoting preferred) are owned by includible corporations
Affiliated group
A controlled group in which ownership constitutes 80% of combined voting power OR total value of stocks
Parent-subsidiary controlled group
A controlled group in which 2 or more corporations in which 5 or fewer persons who are individuals, estates, or trusts own stock possessing
- ) more than 50% of total combined voting power
2) more than 50% of all shares of stock of each corp, only to extent that ownership is identical (i.e. if a SH owns 5% of X and 30% of Y, counted as owning 5% of controlled group)
Brother-sister combined group
A controlled group in whcih the parent in a P-S controlled group is also a member of a brother-sister group of corps
Combined controlled group
Similar to book income, but iscomputed by making adjustments to taxable income by adding back (ex. tax-exempt income, dividends received deduction, excess of MACRS over ADS) and subtracting out (federal income taxes, net capital loss, excess charitable contributions, expenses relating to tax exempt income, penalties)
Current earnings and profits (CEP)
Represents the sum of prior years’ CEP, reduced by distributions and net operating loss of prior years
Accumulated earnings and profits (AEP)