Jerk Flashcards

0
Q

Why did Seagram record a deferred tax liability on its GAAP financial statements as a result of the DuPont transaction?

A

Bc the tax basis of the remaining DuPont shares was far less than the GAAP basis of those shares

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1
Q

How did Seagram account for the DuPont transaction on its GAAP statements?

A

As a sale

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2
Q

As a result of the DuPont transaction, what elements (line items) of Seagrams GAAP financial statements contained amounts that did not coincide with their corresponding economic values?

A

Deferred tax liability and marketable securities

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3
Q

What benefits did Enron’s MIPS transaction provide for Enron?

A

Enron’s MIPS was classified as a hybrid between debt and equity of their F/S, but as debt for tax purposes. Enron was able to deduct these payments as interest.

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4
Q

What was Enron’s stated business purpose with its MIPS transaction?

A

Stated business purpose was to improve debt ratios and reduce the cost of capital

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5
Q

What action did the IRS take with regard to Enron’s transaction?

A

The IRS decided not to challenge

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6
Q

What did the IRS conclude with regard to Enron’s stated business purpose?

A

The IRS conceded that there was a valid business purpose bc the transaction lowered Enron’s cost of capital and improved their financial statements (debt/equity ratio and EPS).

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7
Q

Type II

A

Non deductible IRA

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8
Q

Type IV

A

Taxable brokerage account

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9
Q

Type VI

A

Deductible IRA

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10
Q

Non deductible IRA tax rate

A

Ordinary

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11
Q

Taxable Brokerage account tax rate

A

Capital gains

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12
Q

Which investment vehicle uses the capital loss carry forward?

A

Taxable brokerage account

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13
Q

Why did the decision to make or forgo the 338(h)(10) election in the sale of snapple to Triarc have a $250mm+ after tax cash flow effect?

A

Not making the 338(h)(10) resulted in a $1.4bn loss rather than a gain had it been made. The taxable loss resulted in a refund of prior taxes paid.

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14
Q

If Quaker had spun off snapple, what would have happened to the tax basis that Quaker had in the stock of snapple?

A

It would have vanished

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15
Q

In the actual sale of snapple to Triarc, why didn’t Quaker oats recognize an income tax benefit for GAAP purposes equal to the full amount of the loss multiplied times the corp tax rate?

A

Quaker recognized a valuation allowance on the capital loss carry forward.

16
Q

When Triarc sold snapple to Cadbury, the transaction included a 338(h)(10) election. Why did it make sense in the sale of snapple but not Triarc?

A

Bc the difference btwn the stock and asset basis was much smaller in the sale to Cadbury than in the sale to Triarc.

17
Q

How much did Cadbury pay Triarc to make the 338(h)(10)?

A

About $200mm

18
Q

Estimate gross tax basis

A
  1. Total assets - DTA
  2. # 1 + DTA/.35
  3. # 2 - DTL/.35
  4. # 3 - goodwill*.8

DTA, DTA, DTL - goodwill!!!
Divide, divide, multiply!
2 is add

19
Q

Estimate net tax basis

A
  1. Gross tax basis - total liabilities

2. #1. + DTL

20
Q

What did RH Donnelley have that made it relatively more valuable than some other firms?

A

High tax basis in its assets

21
Q

Approx. how much were the cash tax savings (in discounted) that Bank of America stood to realize from using countrywide’s financial tax losses in the first five years after the acquisition closed?

A

$500mm

22
Q

What type of transaction did Citigroup complete to protect its $43bn of DTA?

A

NOL poison pill

23
Q

How much, in dollars, were the tax benefits for express scripts in the nextRx transaction?

A

$800mm to $1.2bn

24
Q

When does 338 election make sense?

A
  1. Stock basis< asset basis
  2. Stock basis = asset basis
  3. Stock basis > asset basis by small amount
  4. Divesting parent has NOLs
25
Q

When is 338 election sub optimal?

A

Stock basis exceeds asset basis by large amount