TCP Flashcards

1
Q

gain or loss when corp issues stocks in exch for property?

A

No CG/CL if during formation, requisition or resale

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2
Q

what is the basis of the property received by a corporation?

A

The greater of NBV or debt of the corporation

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3
Q

what is corporation’s taxable event income and basis?

A

FMV & FMV

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4
Q

what is corporation’s Nontaxable event income and basis?

A

None, NBV, NNN

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5
Q

Dividends from corporation excess of earning and profit?

A

Return of capital base on Basis or Capital Gains

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6
Q

Current E&P Ratio for quarter dividends

A

Current E&P/Total dividends

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7
Q

what is Section 1245?

A

Sales of depreciable property used in trade or business are OG

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8
Q

AMTI deductions include?

A

Casualty loss from a federally declared disaster

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9
Q

Percentage of foreign stock for U.S person to be a US shareholder?

A

10%

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10
Q

Percentage for Foreign corp to be a “Controlled foreign Corp”?

A

50% ownership of US Shareholders.

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11
Q

gain/loss distributions in complete liquidation of corps taxes?

A

Gain/loss for FMV and gain/loss FMV of assets and Adbasis of stock

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12
Q

entity type to cause higher Income TL of appreciated property?

A

C Corp

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13
Q

how to calculate future taxes with discount factors

A

Tax cost * discount factor

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14
Q

Basis for sale to related party?

A

cost basis of purchase price of buyer

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15
Q

what is Capital Assets?

A

business or personal property of any kind

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16
Q

what is the BEAT rule

A

US Corporation doing business with related foreign affiliates

17
Q

partner’s basis in new partnership?

A

cash + adjusted basis of non cash - 50% of liability of other partners

18
Q

corporation distributes land with her liability than FMV?

A

Use FMV against Basis

19
Q

What is Section 351?

A

No gain/loss is recognized to the transferor/shareholder

20
Q

What is Section 1231 gain

A

Depreciable property and real property in business more than 1 year is subject to LTCG/LTCL

21
Q

What is section 1244?

A

Loss on the sale of the stock can be treated as Ordin loss up to 100k for each shareholder’s join return in any one year

22
Q

what is recognized gain or loss?

A

The less of realized gain or relief from liability (BOOT)

23
Q

Which election must be made at the partnership level?

A

Election of an inventory method

24
Q

When does gift annual exclusion begin?

A

Must be a present amount

25
Q

What is the basis for LLC that has elected to NOT be treated as a corporation?

A

The Basis of the contribution

26
Q

Basis in a nonliquidating distribution?

A

Partner takes basis for assets distributed and cannot exceed the partner’s basis

27
Q

Corporation allocations of distrubition order?

A

Currnet E&P/Accum E&P/Basis deduction/Ordinary income

28
Q

how to determine first q estimate payments?

A

PY total tax liability dividend by 4 for the amount of quaters

29
Q
A