Tax Memorandum 1

Management wants the sale to be reported in fiscal 20X7. The deposit ($6,000,000) was received in May 2007 according to their sales agreement, so it should be reported in 20X7 as unearned revenue because WAL still possesses the land until February 20X8. Once the sale is complete in February 20X8, the income should be reported in fiscal 20X8. After the land is sold, the remaining balance becomes Accounts Receivable until realized.

CHAPTER 21 PARTNERSHIPS SOLUTIONS TO PROBLEM MATERIALS | | | | |Status: | Q/P | |Question/ |Learning | | |Present |in Prior | |Problem |Objective |Topic | |Edition |Edition | | | | | | | | | | | | 1 LO 1 Partnership definition New 2 LO 2 General partnership versus LLC New 3

1 Area used regularly and exclusively for business, regularly for daycare, or for storage of

An amount equal to 90% of the tax for the taxable year calculated by annualizing the taxable income received for the months in the taxable year ending before the month which the installment is required

Beale, Randolph John, (2000) TC Memo 2000-158, RIA TC Memo ¶2000-158, 79 CCH TCM 2001

If Dr. Green 's gambling activities do not qualify as a trade or business, can he deduct his gambling-related travel and lodging expenses against his gambling winnings?

Tiebreaker rules: If a child is claimed as a qualifying child by two or more taxpayers in a given year, the child will be the qualifying child of:

Michala Smith is a single taxpayer, who was gifted a house and 10 acres in the rural area outside of Whitewater. She built a building and started a small country store/bakery on the property. She has made enough income from the store to support herself and save. Michala does not like the idea of paying taxes. She would like to know the best way to structure her sale to meet her goals, which include avoiding taxation and moving on to a different business, such as a bed and breakfast. We recommend that Michala take advantage of Section 121 when selling her home, so that can exclude $250,000 of the gain on the sale. We also recommend that she defers the gain on the sale of her business and land by exchanging it for a bed and breakfast, using

What are the tax implications if the couple sells the photos for $15,000,000 and then claim a charitable contribution deduction on their 2015 joint tax return? Are there any planning strategies to reduce the tax impact of the transaction?

This letter is in response to the tax notice dated October 5, 2015, (copy enclosed) for the $20,000 penalty assessment under IRC Section 6038A(d)(1) for failure to timely provide complete information on Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business for the period ended December 31, 2014. A copy of the executed Power of Attorney is enclosed.

1. All distributions (excluding reasonable salary) to Paula and Mary will be taxed as dividends to them. And the corporation could not deduct this part of distribution.

While it may seem that the dividend compensation is the answer it is important to remember that a C Corporation is not like a partnership or an S Corporation and it is a tax paying entity. As we consider the means of payment for you and your daughter we must also consider the tax implications for the business. Any salary or bonus as well as payroll taxes on the amounts that you and your daughter earn from the corporation can be deducted by the corporation. The new corporate tax rate is 21% down from 35%. On the other side, dividends cannot be deducted by the corporation and therefore there is no benefit to the business for making a dividend

In this report, I will explain the requirements needed to receive an associate’s degree and a

Round Table, Inc. and Avalon Corporation have agreed on a straight B-type reorganization, which will be signed on November 1st, 2015. However, it will not close and take effect until December 31st, 2016, where Round Table will acquire 90% of the issued and outstanding common stock of Avalon in exchange for common stock in Round Table. Avalon currently has 1,000 shares outstanding, all of which are voting common stock, that makeup a $40,000,000 market value ($40,000/share). In addition to the stock for stock agreement, the two entities have engaged in talks of other transactions that could have an effect on the tax-free makeup of a B-type reorganization.

Rebates from suppliers for purchases in later periods were recorded as income in the period the rebate was received or negotiated.