TCP Flashcards
gain or loss when corp issues stocks in exch for property?
No CG/CL if during formation, requisition or resale
what is the basis of the property received by a corporation?
The greater of NBV or debt of the corporation
what is corporation’s taxable event income and basis?
FMV & FMV
what is corporation’s Nontaxable event income and basis?
None, NBV, NNN
Dividends from corporation excess of earning and profit?
Return of capital base on Basis or Capital Gains
Current E&P Ratio for quarter dividends
Current E&P/Total dividends
what is Section 1245?
Sales of depreciable property used in trade or business are OG
AMTI deductions include?
Casualty loss from a federally declared disaster
Percentage of foreign stock for U.S person to be a US shareholder?
10%
Percentage for Foreign corp to be a “Controlled foreign Corp”?
50% ownership of US Shareholders.
gain/loss distributions in complete liquidation of corps taxes?
Gain/loss for FMV and gain/loss FMV of assets and Adbasis of stock
entity type to cause higher Income TL of appreciated property?
C Corp
how to calculate future taxes with discount factors
Tax cost * discount factor
Basis for sale to related party?
cost basis of purchase price of buyer
what is Capital Assets?
business or personal property of any kind
what is the BEAT rule
US Corporation doing business with related foreign affiliates
partner’s basis in new partnership?
cash + adjusted basis of non cash - 50% of liability of other partners
corporation distributes land with her liability than FMV?
Use FMV against Basis
What is Section 351?
No gain/loss is recognized to the transferor/shareholder
What is Section 1231 gain
Depreciable property and real property in business more than 1 year is subject to LTCG/LTCL
What is section 1244?
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
what is recognized gain or loss?
The less of realized gain or relief from liability (BOOT)
Which election must be made at the partnership level?
Election of an inventory method
When does gift annual exclusion begin?
Must be a present amount
