Chapter 4 corporate nonliquidating distributions
Prices starting from /page 100% money back guarantee ENL (US, GB, AU, CA) writers available FREE revisions (Revision Policy) Plagiarism detection system Timely delivery Essays are written from scratch. 1) Corporate distributions that exceed earnings and profits are always capital gains.2) Corporations may always use retained earnings as a substitute for earnings and profits.Corporate shareholders may prefer that the distribution be treated as a dividend, allowing the corporation to take advantage of the special dividends-received deduction under Code § 243 (which allows the dividends to only be taxed once at the corporate level).On the other hand, individual shareholders often prefer that the distribution be treated as a redemption, for three reasons: A distribution qualifies as a stock redemption only if it significantly reduces the interest of the shareholder in the corporation.Ultimately, after studying this text, the reader should have a valuable understanding of the taxation of both C corporations and S corporations.Part I Corporate Formation Chapter 1 Selecting a Business Entity Chapter 2 Transfer of Property to a Corporation Chapter 3 A Corporation’s Capital Structure Chapter 4 Other Corporate Formation Issues Part II Determining Generally a Corporation’s Tax Liability Chapter 5 Calculating Taxable Income Chapter 6 Alternative Minimum Tax and Penalty Taxes Part III Corporate Distributions Chapter 7 Nonliquidating Distributions Chapter 8 Stock Dividends and Stock Redemptions Chapter 9 Liquidating Distributions Part IV S Corporations Chapter 10 S Corporation Eligibility and Operations Chapter 11 Distributions from S Corporations to Shareholders Part V Corporate Mergers and Acquisitions Chapter 12 Taxable Acquisitions Chapter 13 Tax-Free Reorganizations in General Chapter 14 Type A, B, and C Reorganizations Chapter 15 Type D, E, F, and G Reorganizations Chapter 16 Corporate Divisions Chapter 17 Carryovers of Corporate Tax Attributes in Acquisitions Part VI Affiliated Corporations Chapter 18 Affiliated Corporations Part VII Other Corporate Tax Matters Chapter 19 Reportable Transactions and Material Advisors Chapter 20 Overview of International Taxation Appendix I Subchapter C of the Internal Revenue Code Appendix II Subchapter S of the Internal Revenue Code Mr.
Instead of being treated as dividends, redemptions are treated as a sale or exchange of the stock by the shareholder. The distinction can be important when the long-term capital gains rates (which apply to redemptions) are higher than the tax rates on dividends.
Instead, the distribution is governed by the general nonrecognition rule of Code § 311(a), which prevent the corporation from recognizing loss on a transfer of depreciated property. § 302(b)(1), this test is usually used only when the safe harbors of I.
Liquidation is a taxable event for both the shareholder and the corporation. Like the “Redemptions Not Equivalent to Dividends” test of I.
94–455, § 205(c)(1)(B), substituted “1252(a), or 1254(a)” for “or 1252(a)”.
94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”.