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In the current year,Carnation Corporation has a § 179 expense of $20,000.As a result,in the current year,taxable income must be increased by $16,000 to determine current E & P.

A) True
B) False

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What are the requirements that must be satisfied for a distribution to qualify under § 302(b)(2) as a disproportionate redemption?

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To qualify as a disproportionate redempt...

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Renee,the sole shareholder of Indigo Corporation,sold her stock to Chad on July 1 for $180,000.Renee's stock basis at the beginning of the year was $120,000.Indigo made a $60,000 cash distribution to Renee immediately before the sale,while Chad received a $120,000 cash distribution from Indigo on November 1.As of the beginning of the current year,Indigo had $26,000 in accumulated E & P,while current E & P (before distributions) was $90,000.Which of the following statements is correct?


A) Renee recognizes a $60,000 gain on the sale of the stock.
B) Renee recognizes a $64,000 gain on the sale of the stock.
C) Chad recognizes dividend income of $120,000.
D) Chad recognizes dividend income of $30,000.
E) None of the above.

F) A) and C)
G) All of the above

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When does a redemption qualify as a not essentially equivalent redemption under § 302(b)(1)?

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To qualify as a not essentially equivale...

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Reginald and Roland (Reginald's son) each own 50% of the stock of Robin Corporation.Reginald's stock interest is entirely redeemed by Robin Corporation.Two years later,Reginald loans Robin Corporation $250,000.The loan to Robin Corporation does not constitute a prohibited interest for purposes of the family attribution waiver.

A) True
B) False

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Corporate shareholders generally receive less favorable tax treatment from a qualifying stock redemption than from a dividend distribution.

A) True
B) False

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Briefly discuss the rules related to distributions of non-cash property.

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Amounts distributed as dividends in the ...

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When current E & P has a deficit and accumulated E & P is positive,the two accounts are netted at the date of the distribution.If a positive balance results,the distribution is a dividend to the extent of the balance.

A) True
B) False

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In applying the § 318 stock attribution rules to a stock redemption,a shareholder is treated as owning the stock of her spouse,children,grandchildren,parents,and siblings.

A) True
B) False

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Tern Corporation,a cash basis taxpayer,has taxable income of $500,000 for the current year.Tern elected $25,000 of § 179 expense.It also had a related party loss of $20,000 and a realized (not recognized) gain from an involuntary conversion of $75,000.It paid Federal income tax of $150,000 and paid a nondeductible fine of $10,000.Tern's current E & P is:


A) $415,000.
B) $350,000.
C) $340,000.
D) $320,000.
E) None of the above.

F) A) and B)
G) A) and C)

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Maria and Christopher each own 50% of Cockatoo Corporation,a calendar year taxpayer.Distributions from Cockatoo are: $750,000 to Maria on April 1 and $250,000 to Christopher on May 1.Cockatoo's current E & P is $300,000 and its accumulated E & P is $600,000.How much of the accumulated E & P is allocated to Christopher's distribution?


A) $0
B) $75,000
C) $150,000
D) $300,000
E) None of the above

F) A) and D)
G) A) and C)

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Rust Corporation distributes property to its sole shareholder,Andre.The property has a fair market value of $350,000,an adjusted basis of $205,000,and is subject to a liability of $220,000.Current E & P is $500,000.With respect to the distribution,which of the following statements is correct?


A) Rust has a gain of $15,000 and Andre has dividend income of $350,000.
B) Rust has a gain of $145,000 and Andre's basis in the distributed property is $130,000.
C) Rust has a gain of $130,000 and Andre's basis in the distributed property is $350,000.
D) Rust has a gain of $145,000 and Andre has dividend income of $130,000.
E) None of the above.

F) None of the above
G) C) and E)

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To determine current E & P,taxable income must be increased for any domestic production activities deduction.

A) True
B) False

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Falcon Corporation ended its first year of operations with taxable income of $250,000.At the time of Falcon's formation,it incurred $50,000 of organizational expenses.In calculating its taxable income for the year,Falcon claimed an $8,000 deduction for the organizational expenses.What is Falcon's current E & P?


A) $200,000
B) $208,000
C) $250,000
D) $258,000
E) None of the above

F) None of the above
G) B) and D)

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The adjusted gross estate of Keith,decedent,is $12 million.Included in the gross estate is stock in Gold Corporation (E & P of $1.3 million) ,a closely held corporation,valued at $4.6 million as of the date of Keith's death.Keith had acquired the stock twelve years ago at a cost of $900,000.Death taxes and funeral and administration expenses for Keith's estate are $2.3 million.Gold Corporation redeems one-half of the stock from Keith's estate in a § 303 redemption to pay death taxes using property with a fair market value of $2.3 million (adjusted basis of $1.9 million) .Which of the following is a correct statement regarding the tax consequences of this redemption?


A) The estate will have a basis of $2.3 million in the property received from Gold Corporation in redemption of the estate's stock.
B) Gold Corporation will not reduce its E & P as a result of the distribution of the property to Keith's estate.
C) The estate will recognize a $1.4 million long-term capital gain on the redemption.
D) Gold Corporation recognizes no gain (or loss) on the distribution of the property to Keith's estate.
E) None of the above.

F) All of the above
G) None of the above

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Finch Corporation distributes property (basis of $225,000,fair market value of $300,000) to a shareholder in a distribution that is a qualifying stock redemption.The property is subject to a liability of $160,000,which the shareholder assumes.The basis of the property to the shareholder is:


A) $0.
B) $140,000.
C) $225,000.
D) $300,000.
E) None of the above.

F) A) and B)
G) B) and D)

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Stephanie is the sole shareholder and president of Hawk Corporation.She feels that she can justify at least a $220,000 bonus this year because of her performance.However,rather than a bonus in the form of a salary,she plans to have Hawk pay her a $220,000 dividend.Because Stephanie's marginal tax rate is 35%,she prefers to receive a dividend taxed at 15%.Her accountant,however,suggests a $310,000 bonus in lieu of the $220,000 dividend since Hawk Corporation is in the 34% tax bracket.Should Stephanie take the $220,000 dividend or the $310,000 bonus? Support your answer by computing the after-tax cost of the two alternatives to Hawk and to Stephanie.

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Stephanie should choose the $310,000 bon...

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