5 edition of Corporate reorganizations, their federal tax status. found in the catalog.
Corporate reorganizations, their federal tax status.
Holzman, Robert S.
Bibliography: p. 373-378.
|LC Classifications||KF6499.C6 H57 1955|
|The Physical Object|
|Pagination||1 v. (various pagings)|
|LC Control Number||55010669|
See also: Formulary apportionment Some states in the United States require related corporations to file a consolidated return if such corporations constitute a unitary business or unitary group. The update describes recent regulations governing bottom dollar payment obligations, disguised sales of property to or by a partnership, and new rules relating to taxation of foreign partners and partnerships. Foreign profits are thereafter immune from current U. The text focuses on simple partnerships holding few assets and engaging in routine transactions. Franchise Tax Board CA.
The book contains descriptions and analyses of the relevant Internal Revenue Code and Treasury Regulations provisions, summaries of leading cases and IRS rulings, and examples that apply the law to hypothetical situations. Income or excise tax? Students will analyze and reconcile these differences, in order to properly account for them on a company's financial statements. Rules for changing accounting methods and changing accounting periods are also examined as well as issues pertaining to original issue discount. Recapture is required of the gain realized on the asset transfers - to the extent of previously unrecaptured losses of the branch as offset by subsequent gains.
For example, Bigco acquires all of the shares of Smallco from Smallco shareholders in exchange solely for Bigco shares. Tax Rules for Corporate tax rates for tax returns will remain at the higher rates, as will the corporate alternative minimum tax. The reason for choosing that organization is that the concepts embodied in such topics as dividends, earnings and profits, and stock redemptions are the fundamental building blocks on which the more complex provisions of corporate taxation rest. California, following the Barclays case, modified its rules to include in the combined reporting only the taxable income of United States corporations.
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Each chapter contains a basic overview and a detailed analysis. Franchise Tax Board. Transfer of U. The course will cover the tax aspects of a corporation's life-cycle, including a corporation's organization, financing, capital structure, distributions, redemptions, and ultimate liquidation.
Principle Two: Increased federal administrative assistance and cooperation with the states to promote full taxpayer disclosure and accountability. Acquisitive reorganizations: There are many reasons for pursuing a tax-free acquisitive reorganization, such as 1 increasing revenue; 2 improving financial performance particularly if not possible through organic growth ; 3 achieving economies of scale; 4 improving technological capabilities; or 5 expanding into new areas, products, or customer their federal tax status.
book. Demonstrates how the taxation of financial instruments Corporate reorganizations change depending on the taxpayer's role as an investor, dealer, broker, or trader. The text focuses on simple partnerships holding few assets and engaging in routine transactions.
The U. If you are an adopter who is unable to access this content after signing in, contact your account manager for assistance at accountmanager westacademic. Basis must be adjusted for several items, including taxable income or loss recognized by the other member, distributions, and certain other items.
When a shareholder holds several blocks of the same class of stock acquired at different times and at different prices and several distributions are made in complete liquidation, each distribution is allocated among the different blocks in proportion to the number of shares in each block Rev.
Corporate Shares to Foreign Corp. Also, in support of Container, were briefs filed by the U. Law faculty who have created an account can sign in after receiving email notification that registration has been approved. Treatment of the shareholders? The topics covered include: the entity v.
If the property distributed is worth less than the amount of the liability itself, the FMV of the property is treated as no less than the amount of the liability Sec.
Handling Corporate Liabilities Shareholders that assume corporate liabilities or receive property subject to corporate liabilities take the liabilities into account in computing their gain or loss. Shareholders should maintain documentation that multiple distributions are liquidating distributions whenever multiple distributions are necessary especially if they will span several tax years and, therefore, result in tax deferral.
United States federal corporate tax returns require both computation of taxable income from components thereof and reconciliation of taxable income to financial statement income.
Alternative tax options - 1 Tax appreciation when a all, or b certain assets transferred. Tax Rules for Corporate tax rates for tax returns will remain at the higher rates, as will the corporate alternative minimum tax.
On the other hand, filing a request for prompt assessment when there is only one shareholder might not be warranted. It also offers solid coverage of how taxation is affected by international concerns. A reverse triangular merger is commonly used when the target has valuable contracts that would otherwise be canceled if it did not survive the transaction.
Effective tax rates, although usually lower than 35 percent, will likely be lower than 21 percent. The recipients must report the value of the boot as taxable income, and decrease their basis in the new shares by the value of boot received.
And, then, a tax basis adjustment. Between those events, the book discusses operational issues, including the capital structure of a corporation, distributions of cash or property, stock redemptions, and stock dividends. The new partnership audit, assessment and collection rules enacted by the Bipartisan Budget Act of are discussed as well as the associated tax planning.
All members of a consolidated group must use the same tax year. The United States has 13 variations on the basic Form  for S corporationsinsurance companies, Domestic International Sales Corporationsforeign corporations, and other entities.
The corporation is treated as selling the distributed assets for FMV to its shareholders, with the resulting corporate-level tax consequences.Corporate Tax-free Acquisitive Reorganizations p Tax-free exchanges of corporate stock if a proprietary interest is maintained in replacement corporate form.
IRC § provides the definition of tax-free “reorganization” types. U.S. tax common law requirements: 1) Business purpose. A tax-free reorganization may also be deemed to have occurred in other situations, such as the change of the corporate name or state of incorporation, or as a result of a bankruptcy or receivership proceeding.
However, in these types of situations the rules for tax-free reorganizations are normally taken advantage of rather than planned for.
From a very early time, the Internal Revenue Code1 h as permitted taxpayers to form partnerships and corporations tax-free and has allowed mergers of these entities without causing taxation. However, the Code has not and currently does not specifically permit an entity taxed as a partnership to merge with an entity taxed as a corporation, or vice versa, tax-free.2 F or years, taxpayers have.
The corporation is treated as selling the distributed assets for FMV to its shareholders, with the resulting corporate-level tax consequences.
Then, the shareholders are treated as exchanging their stock for the FMV of the assets distributed in complete liquidation, with. U.S. federal income tax return.
Exploration companies should expect an increasing number of inquiries from U.S. shareholders regarding their PFIC status and a heightened focus on PFIC status when an acquisition is contemplated. A Canadian corporation structuring an acquisition may discover for the first time that it is, or has been, a PFIC.
The book is broken into parts on partnership taxation, C corporation taxation, and S corporation taxation.
Each chapter contains a basic overview and a detailed analysis. For each type of business tax entity, the book covers its life cycle — formation, operations, and liquidation — along with reorganizations and divisions for sylvaindez.com: Susan Boland.