Reference no: EM131397014
Assignment
Suppose you are a CPA, and you have a corporate client that has been operating for several years. The company is considering expansion through reorganizations. The company currently has two subsidiaries acquired through Type B reorganizations. The client has asked you for tax advice on the benefit of a Type A, C, or D reorganization over a Type B reorganization. Additional facts regarding the issues are reflected below.
• The company currently files a consolidated income tax return with the two subsidiaries acquired through a Type B reorganization.
• ABC Corporation, a subsidiary targeted by the client for takeover, has substantial net operating losses.
• XYZ Corporation and BB Corporation will be acquired as subsidiaries in the next six months.
Use the Internet and Strayer databases to research the rules and income tax laws regarding Types A, B, C, and D reorganizations and consolidated tax returns. Be sure to use the six step tax research process in Chapter 1 and demonstrated in Appendix A of your textbook as a guide for your written response.
Write a four to six page paper in which you:
1. Compare the long-term tax benefits and advantages of each type of reorganization, and recommend the type of reorganization that will be most beneficial to the client.
2. Suggest the type of reorganization the client should use for the ABC Corporation based on your research. Justify the response.
3. Propose a taxable acquisition structure for the client's planned acquisitions over a nontaxable reorganization. Assess the value of a taxable transaction over a nontaxable reorganization for the client.
4. Examine the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and provide a recommendation to your client. Support the recommendation with applicable research.
5. Create a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group.
6. Use the six step tax research process and demonstrated in Appendix A of the textbook, to record your research for communications to the client.
Your assignment must follow these formatting requirements:
• Be typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides; citations and references must follow APA or school-specific format. Check with your professor for any additional instructions.
• Include a cover page containing the title of the assignment, the student's name, the professor's name, the course title, and the date. The cover page and the reference page are not included in the required assignment page length.
The specific course learning outcomes associated with this assignment are:
• Prepare client, internal, and administrative documents that appropriately convey the results of tax research and planning.
• Evaluate tax-planning strategies related to liquidating distributions, acquisitions, and reorganizations.
• Create an approach to tax research that results in credible and current resources.
• Research and analyze tax issues regarding consolidated tax returns.
• Use technology and information resources to research issues in organizational tax research and planning.
• Write clearly and concisely about organizational tax research and planning using proper writing mechanics.
Suggest a plan for a client to increase the deductible pass
: Suggest a plan for a client to increase the deductible pass through loss and deductions over the initial investment from a new wholly owned S corporation.
|
Simplifying assumptions and comment on sources
: We want to know how many years it would take for the pollution in a lake to reach 5% of its current level, assuming no pollution flows in. Make some simplifying assumptions to estimate this.
|
Spiritual behavior of the second great awakening
: How do you explain the spiritual behavior of the Second Great Awakening as an economist - A possible way to frame your discussion is to start by addressing whether you think the "visions" and other "supernatural" phenomenon were real or not.
|
My physiological reactions to stress identify
: My Physiological Reactions to Stress Identify and describe two situations that were really stressful for you in the past week, times when you were in the physiological alarm phase. Read information about reactions to stress. Discuss the physiological..
|
Examine value and limitations of including abc corporation
: Examine the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and provide a recommendation to your client. Support the recommendation with applicable research.
|
What do you expect to happen to the crude birth rate
: If life expectancy increased by 10 years, what do you expect to happen to the crude birth rate?- Test that Ho : β = 0. If you test that p = 0, will you get the same P value?
|
Analyze the significance of the concept of leadership
: Think about an example of a leader with whom you have worked who has effectively motivated a group. What do you think she or he did and why it was effective? Alternatively, provide an example of a leader who was ineffective at motivating others. W..
|
Difference between positional power and personal power
: You are a new supervisor (you have been there 2 weeks) at a large organization that develops technology for the military. You are retired military and just finished your Bachelor’s Degree in Management. What is the difference between positional power..
|
Develop an influence diagram and a decision tree
: Develop an influence diagram and a decision tree for this situation. What roles do the two diagrams play in helping to understand and communicate the structure of this decision
|