R5 Flashcards
how does shareholders basis change in an S corp based on net income & tax free income
both net income and tax free income will increase a shareholders basis in an S corp.
partners BASE FORMULA
Beg Capital Acct Add+ % of all income Subtract WithDrawls E: ending cap acct \+ % of ALL lab =YE basis
if basis of property in non-cash transaction is greater than partners basis
use the max amount to get the parternship to zero
so if receives property of $6K basis and his initial basis is $5k, since the property > basis before transaction, the property basis would be 5K
Foreign income taxes paid by a domestic corporation may be claimed either as:
a deduction or as a credit, at the option of the corporation.
substantial presence test
foreign person will not meet if they are not present in the U.S. for at least 31 days during the current year and at least 183 days for a three-year period.
what report on Form 1120-F U.S. Income Tax Return of a Foreign Corporation.
Income earned by a U.S. branch is reported on Form 1120-F U.S. Income Tax Return of a Foreign Corporation.
losses from a controlling partner
DISALLOWED.
ex: you own >50% of partnership, and you buy a building with FMV of 10K and partners basis of 20K, you cannot recognize the 10K loss.
so if you own 60%, and the NI is 100k ordinary - 10K loss on building, you need to ADD BACK the 10K loss.
your share as a controlling partner would be 110K60%. everyone else would just be 100K their %