R3: C & S Corp Taxation & Exempt Organizations Flashcards
QPAI Definition and Deduction
“Qualified Production Activities Income” Deduction is equal to the lesser of QPAI or taxable income. QPAI = domestic production or taxable receipts less COGS and allocated overhead (if any)
NOL Rules for corporations
Carryback 2 years, forward 20 years. 2/20 - do not take deduction for charitable contributions but DO take the dividends received deduction when calculating.
How are corporate dividends taxed?
1 - Dividends (taxable) to the extent of current earnings and profits
2 - THEN dividends (taxable) to extend of accumulated earnings and profits
3 - THEN to extent of any related gains (in the case of property dividends)
4 - THEN return of capital (nontaxable)
Corporation capital losses
Are not deductible in excess of capital gains.
Unrelated business income:
1 - Derived from an activity that constitutes a trade or business
2 - is regularly carried on
3 - is not substantially related to the organizations tax-exempt purpose.
Property dividends
Gain is recognized by corporation on property dividends to the extent of FMV in excess of NBV
Corporations basis in contributed land
Adjusted basis of taxpayer contributing plus any amounts paid to secure the land. (i.e. cash in excess)
Percentage of “control” for a tax-free incorporation
80%