What are the U.S. tax consequences of Filigree’s 2003 activity?
Filigree Inc., a foreign corporation, is a wholly owned subsidiary of Gold Corporation, a U.S. corporation. Filigree’s 2003 taxable income of $1 million included $300,000 of Subpart F income. Filigree paid $270,000 of foreign income tax and made no distributions to Gold during 2003. Gold’s separate company 2003 taxable income ...continues
1. As a general rule all of the liabilities of a partnership, including those assumed from a partner, are shared among the partners for purposes of determining outside basis. 2. Partnership liability is recourse to the extent that no partner has personal liability for repayment. 3. If a shareholder owns, directly or indi ...continues
14. The threat of undisclosed or contingent liabilities is minimized if assets are acquired through a merger. 15. As a general rule, a tax-deferred acquisition is financed primarily with stock of the acquiring corporation. 16. Investment banking fees paid by the acquiring corporation as part of a taxable merger are deduc ...continues
Short Case Brief OLD COLONY TRUST CO. v. COM'R OF INTERNAL REVENUE, 279 U.S. 716 (1929)
Short Case Brief OLD COLONY TRUST CO. v. COM'R OF INTERNAL REVENUE, 279 U.S. 716 (1929). See attached file for full problem description.
Ross, a calendar-year, accrual basis S corporation, makes regular and substantial contributions to local tax-exempt charitable organizations. On December 20, its board of directors authorized a $175,000 contribution to the Salvation Children's Clinic. The corporation paid the contribution on January 25. Ross' ordinary business i ...continues
Terms commonly used in tax practice
I am looking for an explanation or definition and maybe a couple examples of: Income from an "Active Business" Income from a "Specified Investment Business" Income from a "Personal Services Business" I am having a hard time understanding what the differences are between the three.
Sharon, a single taxpayer, has taxable income of $100,000, a regular tax liability of $26,560, a positive AMT adjustment due to limitations on itemized deductions of $20,000, and tax preferences of $25,000 in 2006. What is Sharon’s AMT for 2006? Can you please show me step by step how this is calculated?
Case: Gregory v. helvering, 293 US 465 (1935). If you can't open the case you can find at at findlaw.com
Don't let the tax tail wag the dog
The four "maxims" of tax planning are relatively straightforward, and don't need rehashing here. The text also mentions considering "nontax" factors, which is often times a very important and very overlooked aspect of the decision making process. There is a saying common among CPAs that goes "don't let the tax tail wag the ...continues
Relate IRC Sec. 351 to the substance over form doctrine. What purpose does the control requirement of IRC Sec. 351 serve?
