REG- Partnerships & Corps Flashcards
Partnership & Corps
Partnership basis w/ an attached liability
No negative basis. Shareholder gain & Partnership ending basis in property is prop basis + gain
(NBG)
1934 Securities Act statute of limitations
Within 2 years of when should of discovered & within 5 years of fraud
1934 Securities Act 10(b) standard of fraud
Intentional misconduct
Partnership passive losses
Offset indefinitely only against Passive Gains, including rental income
Related losses for Partnerships & Corps
Dissallowed for Partnerships. Corps; <50% dissallowed & >50% loss recognized as Sec 1231 Loss on 1244 Depreciable prop owned <1 year
(No Part-5050)
E&P/Dividend reduction on Property Distribution
= Gain + Relief - FV Prop
GRF
Property Liability exceeds Basis for Corp
Gain to corp
+
Liquidating distribution
Gain = Cash > Basis; Prop Basis = Partnership basis - cash - Inventory or receivable; Shrh Gain = FMV + Cash - Shrh Basis
351 Exchange Corp Formation
Corp Basis = Lower of Transforer basis or FMV + boot
Corp Formation Shareholder stock basis
Transforer basis + gain(>80% ownership) - Boot rec - Liab relief
Accumulated Earnings Tax
20% (add DRD) w/ credit of 250K or 150k Svc co
Exemption = Reasonable $ or AEP - credit $
Personal Holding Co Tax
20% w/ Income <60% passive or Ownership of 5 <50% stock for last half year
E&P Credit
Greater of Resonable needs $ or AEP - 150,000
Taxable Div Income? AEP is negative and E&P positive
Dividend Income to the extent of E&P
Shareholder basis for distributed property
FV of property
