Sign In
Not register? Register Now!
Essay Available:
Pages:
1 page/β‰ˆ275 words
Sources:
No Sources
Style:
APA
Subject:
Accounting, Finance, SPSS
Type:
Coursework
Language:
English (U.S.)
Document:
MS Word
Date:
Total cost:
$ 6.32
Topic:

Discussion: Corporate liquidations and dissolutions

Coursework Instructions:

"Corporate Liquidations, Taxable Acquisition Transactions, and Nontaxable Reorganizations" Please respond to the following:
Question 1 
From the e-Activity, evaluate the appropriateness of the techniques used and the common issues pursued by the IRS in corporate liquidations and dissolutions. Create an argument to defend the client if the IRS pursues the assignment of income doctrine or the clear reflection of income doctrine on a cash-basis corporation, as reflected in the Examining Officers Guide (EOG).
Question 2
IRC Section 338 allows a deemed sale election generating immediate taxation to the target corporation and a stepped-up or stepped-down basis to the price paid by the acquiring corporation for the target corporation stock plus liabilities on the deemed sale. Examine at least one (1) benefit of a Section IRC 338 liquidation election for a target corporation. Create a situation which demonstrates a favorable IRC Section 338 liquidation election for a target corporation.
**********PLEASE FOLLOW THE INSTRUCTIONS********

This is the week 4 e-activity referenced in the questions

 

Go to the Tax Almanac Website, located at http://www(dot)taxalmanac(dot)org/index.php/Tax_Research_Resources, or use the Internet and Strayer databases to research Section 336 of the IRC, Treasury Regulations 1.336, and related judicial decisions. Focus on the appropriateness of the techniques used and the common issues pursued by the IRS in corporate liquidations and dissolutions. Be prepared to discuss


Coursework Sample Content Preview:

Discussion Questions Week 4
Name
Course
Instructor
Date

Corporate liquidations and dissolutions
In recognizing the gain or loss in property in liquidations, there is a need to point out that the fair market value recognized is never below the liabilities value. In many cases, problems arise when identifying the income items to be included in liquidations and dissolutions. In the case of cash-basis corporations, there may be substantial accounts receivable, which may not appear in the books. As such the IRS may rely on the income doctrine or clear reflection of income doctrine to deal with receivables. Under the income doctrine, shareholders have no right to receive income in case of liquidation, and there is a need to clearly reflect income, and this would ordinarily not be allowable in liquidation. If the corporation puts in place plan of complete liquidation and informs the shareholders on the decision to receive distri...
Updated on
Get the Whole Paper!
Not exactly what you need?
Do you need a custom essay? Order right now:
Order

πŸ‘€ Other Visitors are Viewing These APA Coursework Samples:

HIRE A WRITER FROM $11.95 / PAGE
ORDER WITH 15% DISCOUNT!
Order Now