R3/R4 Flashcards
Partnership liquidation distibution
The basis of property received in a liquidating distribution is the adjusted basis less the cash received.
Consolidated returns
When a corporation receives a dividend from its wholly owned subsidiary, the dividend is included in gross income and a 100% dividends-received deduction is allowed. This makes the dividend that was received “taxable” with an offsetting 100% dividends-received deduction allowed, and so makes the net amount equal to zero.
long term capital loss changes its identity
Corporate income tax: When a capital loss is carried to another year, it is treated as a short-term loss. It does not retain its original identity. A corporation can carry a capital loss back three years, but the carryforward period is only five years. Capital losses can only offset capital gains.
Distributions
A distribution from a C corporation to a shareholder cannot be treated by the shareholder as a capital loss. Nonliquidating distributions to a shareholder are recorded at the fair market value on the date of distribution. To the extent of earnings and profit, the distribution is a taxable dividend (i.e., ordinary income). Any excess is a nontaxable return of capital and then a capital gain. Treating the distribution as a capital loss is not an option.
liquidations Question #101214
The shareholder’s basis in property received as a result of a nonliquidating property dividend is the fair market value (FMV) on the date of the distribution. The corporation will recognize a gain for the difference between the FMV on the date of the distribution and the adjusted basis of the property at the date of the distribution. Corporations will not recognize a loss on a nonliquidating property dividend.
Sale of partnership interest #101431
The total gain on the sale of his partnership is $24,000 ($28,000 cash + $15,000 relief of his share of liabilities less basis of $19,000). Unrealized receivables of $6,000 are treated as ordinary income—the remaining $18,000 is capital gain.
Trust
The trust will automatically end on the death of Hardy. A trust terminates when the beneficiary has died. Hardy is the only beneficiary, so the trust expires when he passes.
S corp
The owner’s adjusted basis in the stock of an S corporation is increased by the owner’s share of profits and decreased by the owner’s share of losses, and is not affected by the entity’s bank loan increases and decreases.
The owner’s adjusted basis in a partnership is increased by the owner’s share of profits and decreased by the owner’s share of losses, and is also increased for the partner’s share of partnership debt.
The owner’s adjusted basis in a C corporation’s stock is not adjusted for income or loss of the C corporation.
The members of a limited liability company do not bear personal liability for its debts.
LLC VS Scorp Question #101217
n S corporation recognizes a gain on the distribution of appreciated property to a shareholder. The transaction is treated as a “sale” of the property to the shareholder at fair market value (FMV).
Distributions from a limited liability company (LLC) are assigned a portion of adjusted basis of the LLC interest.
Method of accounting
A C corporation with sales over $5 million must use the accrual method of accounting. Therefore, because Dart is a C corporation with sales over $20 million per year for the past three years, Dart must use the accrual method.
Partnership termination
When a partnership terminates yet some of the partners continue the partnership, there will have been a “deemed” distribution from the old partnership and a “deemed” recontribution of assets to the new partnership. Therefore, both statements I and II are true.
Tax exempt interest 101373
Not included in partnership income but added to basis
Corp liquidation
When a corporation completely liquidates, the corporation will recognize a gain or loss “as if” the property were sold at fair market value.
Question #101599 c v S corp incom
look into question
liquidation- Question #101455
allocaton basiss