R5 Flashcards
An S corporation has two shareholders who are also employees of the corporation.
Shareholder A owns 20 shares and shareholder B owns 90 shares. The total number of shares issued and outstanding is 2,000. The corporation pays the health insurance premiums for all its employees and families. The cost of family coverage is $5,300. The corporation pays for family coverage for both shareholders. Because the company paid for health insurance, which of the following amounts would be reported to Shareholder A as his income?
The value of fringe benefits such as health insurance is includable in the gross income of S corporation shareholders who own more than 2 percent of the S corporation’s stock (unless the S corporation does not deduct the cost of such benefits).
In this case, Shareholder A only owns 1 percent of the S corporation’s stock
(20 shares/2,000 shares = 1 percent).
Thus, Shareholder A is not required to include the value of the health insurance in his gross income
The basis to a partner of property distributed “in kind” in complete liquidation of the partner’s interest is the
Adjusted basis of the partner’s interest reduced by any cash distributed to the partner in the same transaction.
Rule:
Upon dissolution, the “basis” of property distributed to a partner will be the
partner’s “adjusted basis” in the partnership, net of any cash distributions (not FMV of property distributed).
Garner is a 25 percent partner in Classic General Partnership. On February 3, Garner’s tax basis in Classic was $10,000 when she received a nonliquidating distribution of $5,000 cash. Classic had no unrealized receivables, appreciated inventory, or properties that had been contributed by its partners. Classic reported the following for
the same year:
U.S. Treasury interest $ 30,000
Ordinary business income 120,000
What amount of income from Classic should Garner include in her gross income for that
year?
Garner’s 25 percent share of the partnership’s $120,000 ordinary
business income is $30,000.
Her 25 percent share of the partnership’s $30,000 U.S.
Treasury interest is $7,500.
These are both included in Garner’s gross income for the year.
A nonliquidating cash distribution is a nontaxable return of capital to the extent
that the partner has basis in his or her partnership interest. Because Garner’s basis in her partnership interest is more than the $5,000 cash distribution, the distribution is
nontaxable.
Garner’s total gross income for the year is $30,000 + $7,500 = $37,500
S corporation status become effective?
An S corporation election made by the 15th day of the third month of the year can be retroactive to the beginning of the
year. Any election made subsequent to that date is effective as of the first day of the next year
what does “Hot assets” of a partnership would include?
Hot assets are:
(1) Unrealized receivables and,
(2) Appreciated inventory.
As a general rule, a partner who sells or exchanges his or her partnership interest has a recognized capital gain or loss.
The capital gain or loss is measured by the difference between the amount realized for the sale and the adjusted basis of the partnership interest.
An exception to the capital gain treatment is on any gain that represents a partner’s
share of “hot assets”. Any gain that represents a partner’s share of hot assets is treated as ordinary income
Turner, Reed, and Sumner are equal partners in TRS partnership. Turner contributed land with an adjusted basis of $20,000 and a fair market value (FMV) of $50,000. Reed contributed equipment with an adjusted basis of $40,000 and an FMV of $50,000. Sumner provided services worth $50,000. What amount of income is recognized as a result of the transfers?
Generally, no gain or loss is recognized on a contribution of property to a partnership in return for a partnership interest (note: when contributed property is subject to a liability, if the decrease in the contributing partner’s individual basis exceeds the partner’s partnership basis, the excess amount is treated like taxable boot and is a gain to that partner).
So, given the facts in this question, Turner and Reed will recognize no income or gain.
On the other hand, the value of a partnership acquired for services is ordinary income to the partner rendering those services. So, Summer must recognize $50,000 of ordinary income on account of Summer’s rendering to the partnership services in exchange for a partnership interest with a FMV of $50,000.
Hunter contributed artwork in exchange for a partnership interest. The artwork had an
adjusted basis of $7,000,
a fair market value of $50,000,
subject to a loan of $5,000.
What is the partnership’s basis in the artwork?
The partnership’s basis in the artwork is $7,000.
A partnership’s basis in property contributed by a partner is the same as the partner’s adjusted basis in
the property.
George and Martha are equal partners in G&M Partnership.
At the beginning of the current tax year, the adjusted basis of George’s partnership interest was $32,500,
which included his share of $40,000 of partnership liabilities.
During the tax year, the following
information applied to G&M:
Operating loss === 30,000
Interest and dividend income === 8,000
Partnership liabilities at end of year=24,000
What was the basis of George’s partnership interest at year-end?
A partner’s share of operating losses reduces that partner’s basis.
Likewise, a reduction in a partner’s share of liabilities reduces basis.
A partner’s basis will increase by that partner’s share of income such as dividends and interest.
Initial basis in partnership interest ==32,500
Equal share of interest and dividends 4,000
Equal share of operating loss ===== (15,000)
Share of decreased partnership liabilities at
year-end==== (8,000)
(George’s partnership interest was $32,500,
which included his share of $40,000 of partnership liabilities. which is supposed to be 20,000 from the 40k. Then year end liabilities of partnership is 24,000 and 12,000 is G’s share. Therefore 20,000-12,000 = 8000)
Basis of George’s partnership interest at year-end ==== 13,500
Apply limitations in determining a partner’s deduction for the partner’s share of partnership losses?
- AT - RISK
- Passive losses
S-corp Shareholders consent
All the shareholders must be agreed upon in writing for an S-corp election to be valid
DomCo (a domestic corporation) owns 100 percent of ForCo (a foreign corporation),
which operates outside of the United States. Which of the following statements is
correct?
ForCo’s Subpart F income will generally be treated as deemed dividend subject to immediate recognition by DomCo.
Because ForCo is a CFC, certain types of income (e.g., passive investment income) earned are subject to immediate taxation
Baker is a partner in BDT with a basis in his partnership interest of $60,000. BDT made a liquidating distribution of land with an adjusted basis of $75,000 and a fair market value of $40,000 to Baker. What amount of gain or loss should Baker report?
Ans == 0
In a complete liquidation of a partnership, a partner (Baker) recognizes gain only to the extent that money received (if any) exceeds the partner’s adjusted basis in the partnership interest immediately before the distribution.
In this question, there is no money distributed, so there is no gain recognized.
The partner recognizes loss if only money, unrealized receivables, or inventory are received and if the basis of the assets received is less than the partner’s basis in the partnership interest. In this question, there is no money, unrealized receivables, or inventory distributed, so there is no loss recognized, regardless of the partner’s basis in the partnership interest.
Even though the land has a $40,000 fair market value, Baker’s basis in the land is his $60,000 basis in the partnership interest, effectively giving him a $20,000 built-in loss that he can recognize by selling the land.
Partnerships —-terminate
Partnerships terminate by cessation of partnership activities and liquidation, or when the partnership’s business activities no longer continue in partnership form, or when there are fewer than two partners. Changes in ownership do not terminate partnerships if at least two partners remain.
A partner sold a 25 percent interest in a partnership for $400,000 cash plus assumption of the partner’s share of the partnership liabilities. The following additional information relates to the partnership activities:
Partner’s initial cash contribution $ 100,000
Partnership income during the partner’s ownership time period 1,000,000
Partnership liabilities at date of sale 60,000
Partner’s cash withdrawals 50,000
How much gain is recognized by the partner upon the sale of the partnership interest?
The gain recognized by the partner on the sale of the partnership interest is $100,000, which is the difference between the amount realized on the sale and the adjusted basis of the partnership interest at the date of the sale.
Amount realized:
Cash sales price $ 400,000
Relief from partnership liabilities
(60,000 × 25%) 15,000
$415,000
Adjusted basis in partnership interest:
Initial cash contribution $100,000
Share of partnership income
(1,000,000 × 25%) 250,000
Share of partnership liabilities
(60,000 × 25%) 15,000
Partnership distributions (50,000)
$315,000
Amount realized $415,000
Adjusted basis in partnership interest
(315,000)
Gain recognized on sale of partnership interest $100,000
S-CORP - BUILT IN GAIN
The tax on BIG is a corporate level tax on the S Corp that dispose of assets that are
Appreciated while the company was a
C-CORP