Corporate Taxation
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| Minimum tax credit | show 🗑
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| AMT small corp., exemption | show 🗑
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| show | adj. curr. earngs (ACE-preACE if neg. is lim to PY pos.)= preACE AMTI b4NOL+exempt int., exempt life benef. +70%DRD-cost completion depl.-ADS depr-/+cap'd org& circulation exps., +(FIFO-LIFO), no installment mthd for non-dealers, intangibles amort 5 yrs
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| show | if own >80% then all divs excluded from tax, >20% exclude80%, <20% exclude 70% All subject to TI lim., debt financed stock NTE interest deduction, held <46days, no DRD for personal srvcs and holdco's
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| Non-deductible stock issuance costs | show 🗑
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| Corporate charitable contribution | show 🗑
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| show | reductions are contingency reserves , dividends, etc., INCREASES are state refunds from years before last.
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| show | #83 div distribution does NOT affect AEP deficit, but reduces positive AEP
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| show | treated as sale @ FMV, if liability assumed by shareholder more than FMV, then corp's gain=liab-BV (losses are not recognized)
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| show | corp has to recognize gain on prop distribution in excess of basis, which increases AEP. Taxable divs., to stockholder is the AEP+CEP(due to the gain), if excess the return of capital.
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| Corp's sale to shareholder prop for less than FMV | show 🗑
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| Complete liquidation of shareholder interest in a corp | show 🗑
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| show | does NOT essentially=divs, 2 substantially disproportionate, 3 terminates shareholder interest, 4 partial liquidation,5 to pay death tax
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| show | only the interest is deductible, other fees NON-deductible , unless complete liquidation, then ORDINARY
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| Corp liquidation of a sub | show 🗑
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| show | all capital gain at FMV( property and inventory)
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| show | if corp earns 60% passive income (excluding tax exempt) & fewer than 5 people own 50% of the corp then in addition to reg tax 15% on undistributed PHC income
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| show | imposed on corps @ 15% on earnings accumulated beyond reasonable business needs. Credit is 250k-PYaccum.earnings, or reasonable business needs stmnt
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| Tax-free Reorganization of corps., A,B,C,D, E, F,G | show 🗑
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| show | securities exchanged by corps that are NOT parties to reorg.
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| show | P's TI*days owned/365; Sec382, if acquired >50%, FMVofStck*fedTaxExemptRate*days owned/365
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Created by:
baurjan
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