Create a tax-planning strategy for a client geared

Assignment Help Taxation

Reference no: EM131175370

Discussion 1 and 2

Discussion 1

A client is pursuing the acquisition of Corporation A that has a substantial net operating loss. Corporation B is a member of the controlled group and is currently included in the consolidated tax return that also has a net operating loss. Analyze the potential advantages and disadvantages of Corporation B's acquisition of Corporation A and Corporation A's subsequent inclusion in Corporation B's consolidated tax return. Suggest the key tax issues the client should consider in determining the deductibility of the net operating losses.

From the e-Activity, create a tax-planning strategy for a client geared toward complying with the final regulations issued by the IRS under Code Section 267 (f). (Note: Code Section 267 (f) discusses the time taken into account for deferred losses on the sale or exchange of property between members of a controlled group.) Recommend the alternatives that you believe would be best suited for the client to use in order to both take advantage of losses between members and remain in compliance with related regulations. Justify your response.

Discussion 2

Corporations P, S, and C are members of a parent-subsidiary controlled group filing a consolidated tax return. Corporations A and B are members of a brother-sister controlled group that cannot file a consolidated tax return. Design a strategy geared toward creating an affiliated group which makes Corporations A, B, P, S, and C all eligible to file a consolidated tax return.

Assess the adequacy of the schedule M-3 Part 1 in creating transparency between the consolidated financial statements and the consolidated tax returns of the corporations discussed in the first part of this discussion. Suggest at least two modifications to the M-3 that you can use to identify possible issues the IRS would most likely examine on a consolidated tax return.

Reference no: EM131175370

Questions Cloud

What is media literacy and why is it important : In what ways did your examples shape, change, or reinforce your own cultural values?- What is media literacy and why is it important?

Identify one consequence of a nontaxable reorganization : Identify one consequence of a nontaxable reorganization, and offer an alternative to eliminate the negative effect of the identified consequence.

How do these practices interrelate to further reduce risk : Compare and contrast the four priorities for best safety practices for fire safety discussed in the unit. How do these practices interrelate to further reduce risk? Of the four priorities, which do you believe is the least used by building manage..

How incorporation by reference affect enforcement of nfpa : Discuss how these standards and guidelines interface with each other. Review 29 CFR 1910.6 at http://www.osha.gov to see which NFPA guidelines have been incorporated by reference. How does incorporation by reference affect the enforcement of NFPA ..

Create a tax-planning strategy for a client geared : From the e-Activity, create a tax-planning strategy for a client geared toward complying with the final regulations issued by the IRS under Code Section 267 (f).

What is wrong with phillips curve and how can it be mended : How does Hayek's (1948) article "The Use of Knowledge in Society", AER, vol. 35, nr. 4, pgs. 519-30, change your view of the functioning of an economy? What is wrong with the Phillips curve and how can it be mended

What is the expansion factor of this scheme : What is the expansion factor of this scheme and what are its visual threshold values?

Why congress allowed the exception to the calendar year : The IRC restricts the choices for a partnership‘s tax year to prevent the deferral of tax. Suggest at least one major reason why Congress allowed the exception to the calendar year for partnership tax year elections.

Is this a transportation accident : As a container of hazardous materials is being unloaded from a delivery truck, the container is dropped and the package begins to leak. Is this a transportation accident? Why, or why not? Explain the actions required to be taken by the driver in s..

User Account

All Pages