User Account

All Pages

Corporate Taxation, Taxation

Assignment Help:
1. L has business assets worth $6,000,000, NOL carryovers of $1,000,000 expiring in 14 years, and NOL carryovers of $1,400,000 expiring in 15 years. 100% of L’s stock is worth $8,000,000. The long-term tax exempt rate is 5%. The current third party market interest rate is 6%. Commercial bank mortgage rates are 3%.
(a) What will the § 382 limitation be if an ownership change occurs with respect to L’s stock? Assuming sufficient taxable income, how long will it take to fully utilize the NOLs?

IRC §382(g) explains the limitations if an ownership change occurs in respect to a corporation’s stock. There is a limit on the use of NOLs when there is a change in ownership of more than 50% of stock over a max three-year period.

(b) Same questions and facts as (a) above, except L has minimal assets and 100% of its stock is worth $2,000,000.


2. A owns all of the stock of X with a basis of $200. A’s three sons own all of the stock of Y equally. X and Y each have 100 shares of common stock outstanding (worth $4 each) and E&P of $100, respectively. A sells one half of the X stock to Y for $200.

(a) What is the amount and character of income or loss to A on this transaction?

(b) Would your answer change if X, rather than A’s three sons, owned all of the stock of Y? Why or why not?


3. Corporation is owned by Abby (30 shares, $30,000 basis), Bennett (30 shares, $30,000 basis), and Candice (40 shares, $40,000 basis), who are unrelated. X has an earnings and profits deficit for the current year of $10,000 and accumulated earnings and profits (excluding the current year deficit) of $220,000. X plans to completely liquidate in the current year.

(a) What are the tax consequences to Abby if X distributes a piece of equipment used in X’s business with a fair market value of $25,000 to Abby in exchange for her stock as part of the complete liquidation of X. (Assume X will also make similar distributions to Bennett and Candice).

(b) What are the tax consequences to X of the distribution to Abby? X’s basis in the equipment was $36,000. X bought the equipment new six years ago.

Related Discussions:- Corporate Taxation

Role of media play in marketing mix, Role of media play in marketing mix: ...

Role of media play in marketing mix: A. The article discusses the market prospects for automotive technology for producing driverless cars with the potential to reduce road ac

Tds, Dawn's new car has a FMV of $20,000 and it weighs 3,000 pounds. The co...

Dawn's new car has a FMV of $20,000 and it weighs 3,000 pounds. The county also assessed a property tax on the car. The tax was 2% of its FMV and $10 per hundred weight. The car is

Effects of a tax on producers of corn syrup, In response to rising obesity,...

In response to rising obesity, a number of pundits have proposed taxing corn syrup, an ingredient in most soda pop. Let's consider the market for corn syrup assuming this tax take

Tax Individuals , Hi Dear, Could you please help me with lots of assignmen...

Hi Dear, Could you please help me with lots of assignments in Tax Individuals within 2 hours. That mean I will send you my questions and the experts will solve the questions with

Calculate the change output growth , Utilize Okun's law to answer the quest...

Utilize Okun's law to answer the questions below;  u t  - u t-1  = -0.4(g yt  - 3%) Assuming u t-1  = 7% a. Calculate the change in u (u t  - u t-1 ) for each of the followin

Explain the effects of taxation on the equilibrium of a firm, Q. Explain th...

Q. Explain the effects of taxation on the equilibrium of a firm? Suppose a tax is imposed on the producers of a commodity, the tax is on each unit for they produce. Naturally,

Explain the motivations behind debt covenants, Explain the motivations behi...

Explain the motivations behind debt covenants: You are engineering a Leveraged-Buy-Out (LBO) of ACME Industries, an industrial bottle maker. After the LBO, the firm will be fina

The effect of the disposition, At the beginning of 2010,Marquee Inc. has tw...

At the beginning of 2010,Marquee Inc. has two assets in Class 10 . The balance in this class is $7,423. The cost of each asset in the class was $7,500. On June 30, 2011, one of the

Recognized gain or allowable loss, I need help determining the character of...

I need help determining the character of the recognized gain or allowable loss in each of the cases listed below. In each case, these are all of the tax payer realized gains or los

What are the tax status of the property, Miguel receives tangible personal ...

Miguel receives tangible personal property as an inheritance in 2011. The property was depreciated by the deceased (Miguel's father), and Miguel will also depreciate it. At the dat

Write Your Message!

Captcha
Order Assignment

Featured Services

Order Now

Popular Subjects

Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

Submit Assignment

Academics

Major Subjects

Majors

Get In Touch

whatsapp: +91-977-207-8620

Phone: +91-977-207-8620

Email: [email protected]

TERMS & POLICIES

HELP & SUPPORT

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd