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business
taxation of individuals
Questions and Answers of
Taxation of Individuals
When a partner's share of partnership liabilities increases, that partner's basis in the partnership interest:a. Increases by the partner's share of the liabilities.b. Decreases by the partner's
At the inception of a partnership, Black acquires a 50% interest in Decorators Partnership by contributing property with an adjusted basis of $250,000. Black recognizes a gain if: I. The fair market
Duffy Associates is a partnership engaged in real estate development. Olinto, a civil engineer, billed Duffy $40,000 in the current year for consulting services rendered. In full settlement of this
Nick, Chris, Stacey, and Mike are each 25% partners in Liberty Partnership, a general partnership. During the current year, the partnership had revenues of $300,000 and nonseparately allocated
Gray is a 50% partner in Fabco Partnership, Gray's tax basis in Fabco on January 1, year 4, was $5,000. Fabco made no distributions to the partners during year 4 and recorded the following. Ordinary
Construct a graph that shows the increases in the numbers of LICS and LIPS filing Federal tax returns for five-year periods beginning with 1970. Explain any trends in the data that you identify. Send
Determine the statutory tax treatment in your state of a one- member LLC. Write an e-mail to your professor comparing this rule with Federal tax law.Research Problem
Find a blog that concentrates on the taxation of partners and partnerships. Post a message defining the terms inside basis and outside basis and illustrating why the distinction between them is
Find an article posted by a law firm that comments on pitfalls to avoid in drafting partnership agreements. Ideally, use the home page of a firm that has offices in your state. Summarize the posting
Barney Chang and Aldrin, Inc., a domestic C corporation, have decided to form BA LLC. The new entity will produce a product that Barney recently developed and patented. Barney and Aldrin each will
Fredstone Consolidated, Inc., and Gradison Enterprises, Inc., are both real estate developers. Each entity owns a 50% general partner interest in Realty Partners, GP, a general partnership. Fredstone
To what extent are the personal assets of a general partner, limited partner, or member of an LLC subject to (a) contractual liability claims, such as trade accounts payable, and (b) malpractice
Jim Dunn, Amy Lauersen, and Tony Packard have agreed to form a partnership. In return for a 30% capital interest, Dunn transferred machinery (basis $268,000, fair market value $400,000) subject to a
What is the function of a partner's capital account under the rules of generally accepted accounting principles (GAAP)? What is the partner's initial balance in the capital account? How and when does
LO.4 The Sparrow Partnership plans to distribute $200,000 cash to its partners at the end of the year. Marjorie is a 40% partner and would receive $80,000. Her basis in the partnership is only
LO.2, 4, 5, 8 Continue with the facts presented in Problem 31, except that Suz-Anna was formed as an LLC instead of a general partnership.a. How would Suz-Anna's ending liabilities be treated?b. How
LO.2, 4, 5 Suzy contributed assets valued at $360,000 (basis of $200,000) in exchange for her 40% interest in Suz-Anna GP (a general partnership in which both partners are active owners). Anna
LO.4, 5, 7 At the beginning of the tax year, Melodie's basis in the MIP LLC was $60,000, including Melodie's $40,000 share of the LLC's liabilities. At the end of the year, MIP distributed to Melodie
LO.5 In each of the following independent cases in which the partnership owns no hot assets, indicate the following. All of the partners received proportionate distributions. . Whether the partner
LO.4, 7 Mona and Denise, mother and daughter, operate a local restaurant as an LLC. The MD LLC earned a profit of $200,000 in the current year. Denise's equal LLC interest was acquired by gift from
LO.7 Burgundy, Inc., and Violet Gomez are equal partners in the calendar year BV LLC. Burgundy uses a fiscal year ending April 30, and Violet uses a calendar year. Burgundy receives an annual
LO.7 Four GRRLS Partnership is owned by four unrelated friends. Lacy holds a 40% interest; each of the others owns 20%. Lacy sells investment property to the partnership for its fair market value of
LO.2, 3 The Pelican Partnership was formed on August 1 of the current year and admitted Morlan and Merriman as equal partners on that date. The partners both contributed $300,000 of cash to establish
LO.5, 6 The BCD Partnership plans to distribute cash of $20,000 to partner Barb at the end of the tax year. The partnership reported a loss for the year, and Barb's share of the loss is $10,000. Barb
LO.2, 5 Assume the same facts as in Problem 21, except that the property contrib- uted by Lee has a fair market value of $27,500 and is subject to a nonre- course mortgage of $20,000.a. What is Lee's
LO.2, 5 Lee, Brad, and Rick form the LBR Partnership on January 1 of the current year. In return for a 25% interest, Lee transfers property (basis of $15,000, fair market value of $17,500) subject to
LO.2, 4, 5 The JM Partnership was formed to acquire land and subdivide it as resi- dential housing lots. On March 1, 2018, Jessica contributed land valued at $600,000 to the partnership in exchange
LO.3 Cerulean, Inc., Coral, Inc., and Crimson, Inc., form the Three Cs Partnership on January 1 of the current year. Cerulean is a 50% partner, and Crimson and Coral are 25% partners. For reporting
LO.4, 5 Continue with the same facts of Problem 16. Consider Amy's tax-basis capital account.a. What is Amy's capital account at the beginning of the year?b. What is Amy's capital account at the end
LO.4, 5 Assume the same facts as in Problem 16. What income, gains, losses, and deductions does Amy report on her income tax return? Based on the infor- mation provided, what other calculations is
LO.4, 5 Amy and Mitchell share equally in the profits, losses, and capital of the accrual basis AM Products LLC. Amy is the managing member of the LLC (treated as a general partner) and is a U.S.
LO.2, 4 Phoebe and Parker are equal members of Phoenix Investors LLC. They are real estate investors who formed the entity several years ago with equal cash contributions. Phoenix then purchased a
LO.3 On July 1 of the current year, the R&R Partnership was formed as a limited partnership to operate a bed-and-breakfast inn. The partnership paid $3,000 in legal fees for drafting the partnership
LO.2 Continue with the facts presented in Problem 12. At the end of the first year, SD distributes $100,000 cash to Sam. No distribution is made to Drew. How does Sam treat the payment?a. C.b. How
LO.2, 5 Sam and Drew are equal members of the SD LLC, formed on June 1 of the current year. Sam contributed land that he inherited from his uncle Garza in 2009. Garza had purchased the land in 1984
LO.2 Liz and John formed the equal IJ Partnership on January 1 of the current year. Liz contributed $80,000 of cash and land with a fair market value of $90,000 and an adjusted basis of $75,000. John
LO.2 Kenisha and Shawna form the equal KS LLC with a cash contribution of $360,000 from Kenisha and a property contribution (adjusted basis of $380,000, fair market value of $360,000) from Shawna.a.
LO.2 Emma and Laine form the equal EL Partnership. Emma contributes cash of $100,000. Laine contributes property with an adjusted basis of $40,000 and a fair market value of $100,000.a. How much
LO.2 Janda and Kelsey contributed $1 million each to the JKI, LLC in exchange for 45% capital and profits interests in the entity. Lilli will contribute no cash, but has agreed to manage the LLC's
LO.4 When Bruno's basis in his interest in the MNO LLC is $150,000, he receives cash of $55,000, a proportionate share of inventory, and land in a distribution that liquidates MNO and his interest in
LO.4 Franco owns a 60% interest in the Dulera LLC. On December 31 of the current tax year, his basis in the LLC interest is $128,000. The fair market value of the interest is $140,000. Dulera then
LO.3 Candlewood LLC began its business on September 1; it uses a calendar tax and accounting year. Candlewood incurred $6,500 in legal fees for drafting the LLC's operating agreement and $3,000 in
LO.5 At the beginning of the tax year, Barnaby's basis in the BBB Partnership was $50,000, including his $5,000 share of partnership debt. At the end of the tax year, his share of the entity's debt
LO.2 Wozniacki and Wilcox form Jewel LLC, with each investor receiving a one-half interest in the capital and profits of the LLC. Wozniacki receives his one-half interest as compensation for tax
LO.2 Henrietta transfers cash of $75,000 and equipment with a fair market value of $25,000 (basis to her as a sole proprietor, $10,000) in exchange for a 40% profit and loss interest worth $100,000
LO.4 Enerico contributes $100,000 cash in exchange for a 40% interest in the calendar year ABC IIC. This year, ABC generates $80,000 of ordinary taxable income. Enerico withdraws $10,000 cash from
Explain how LLPs and LLCs differ and list the tax advantages and disadvantages of using an LLC.
Apply the tax laws regarding transactions between a partner and the partnership.
Apply the tax law's limitations on deducting partnership losses.
Determine a partner's basis in the partnership interest.
Calculate partnership taxable income and describe how partnership items affect a partner's income tax liability.
Determine the tax treatment of expenditures of a newly formed partnership and identify elections available to the partnership.
Apply the tax rules regarding the formation of a partnership with cash and property contributions.
Identify governing principles and theories of partnership taxation.
In which of the following cases will Federal law prohibit a state from imposing tax on net income?a. The business has a retail outlet store in the state.b. The business has its corporate headquarters
Identify three states considered to be in the same economic region as your own.a. For each of the three states and your own state, answer the following ques- tions, creating a table with your
Read the "tax footnote" of five publicly traded U.S. corpora- tions. Find the effective state/local income tax rates of each. Create a PowerPoint presentation (maximum of five slides) for your
Locate data on the size of the international economy, including data on international trade, foreign direct investment of U.S. firms, and investments in the United States by foreign firms. Useful
For your analysis, choose 10 countries, one of which is the United States. Create a table showing whether each country applies a worldwide or territorial approach to international income taxation.
Make a list of five countries with which the United States does not have in force a bilateral income tax treaty. Research Problem
Supervise and Wager Company produces consumer goods that are distributed and sold primarily in North America, Europe, and Asia. The business includes a U.S. parent company, S&W, Inc., and separate
Polly Ling is a successful professional golfer. She is a resident of a country that does not have a tax treaty with the United States. Ling plays matches around the world, about one-half of which are
Jerry Jeff Keen, the CFO of Boots Unlimited, a Texas corporation, has come to you regarding a potential restructuring of business operations. Boots long has manufactured its western boots in plants
The trend in state income taxation is to move to an apportionment formula that places extra weight on the sales factor. Several states now use sales-factor-only apportionment. Explain why this
Write a paper of no more than two pages discussing the treatment of state and local taxes that is found in the text of U.S. income tax treaties with two other countries.
What type of information-sharing agreements does the IRS have with the revenue agency of the Bahamas? Canada? Germany? Israel? Argentina?
LO.3,7 Miha Ohua is the CFO of a U.S. company that has operations in Europe and Asia. The company has several manufacturing subsidiaries in low-tax foreign countries where the tax rate averages 6%.
LO.6 Prepare a PowerPoint presentation (maximum of six slides) entitled "Plan- ning Principles for Our Multistate Clients." The slides will be used to lead a 20-minute discussion with colleagues in
LO.6 Hernandez, which has been an S corporation since inception, is subject to tax in States Y and Z. On Schedule K of its Federal Form 11205, Hernandez reported ordinary income of $500,000 from its
LO.6 State A enjoys a prosperous economy, with high real estate values and compensation levels. State B's economy has seen better days-property val- ues are depressed, and unemployment is higher than
LO.6 Repeat the computations of Problem 36, but now assume that State A is a sales-factor-only state and that State B uses the following weights: sales .70, payroll .15, and property .15.
LO.6 Repeat the computations of Problem 36, but now assume that State B uses a double-weighted sales factor in its apportionment formula.
LO.6 PinkCo, Inc., operates in two states, both of which equally weight the three apportionment factors. PinkCo reports the following results for the year. Com- pute the apportionment percentage for
LO.6 Continue with the facts of Problem 34. Using the format of Exhibit 16.3. compute state taxable income for HippCo, assuming also that the taxpayer recognized $225,000 of net rent income during
LO.6 Compute state taxable income for HippCo, Inc. Its Federal taxable income for the year is $1 million. Its operations are confined to Oregon and Montana. HippCo generates only business and
LO.5 Continue to consider the case of the taxpayer in Problem 32. Is it acceptable to you if Norris purposely shifts its sales force among the states to reduce its tax liabilities? In your response,
LO.5 Considering only the aggregate state income tax liability, how should Norris, who sells widgets from its domicile State A, deploy its sales force? The states that entail the taxpayer's entire
LO.5 You are working with the top management of one of your clients in selecting the U.S. location for a new manufacturing operation. Craft a plan for the CEO to use in discussions with the economic
LO.5 Evaluate this statement: A state can tax only its resident individuals and the corporations and partnerships that are organized in-state.
LO.3 Warwick, Inc., a U.S. corporation, owns 100% of NewGrass, Ltd., a foreign cor- poration. NewGrass earns only general limitation income. During the current year, NewGrass paid Warwick a $10,000
LO.3, 4 Write a memo for the tax research file on the difference between "inbound" and "outbound" activities in the context of U.S. taxation of international income.
LO.4 Evaluate the following statement: Non-U.S. persons never are subject to U.S. taxation on U.S.-source investment income, so long as they are not engaged in a U.S. trade or business.
LO.4 Give a simple answer to Andre's question: "If I move to the United States, how will the Federal government tax my widget sales and capital gains?" Andre will be living in New York City, where
LO.3 HiramCo, a U.S. entity, operates a manufacturing business in both Mexico and Costa Rica, and it holds its investment portfolio in Sweden. How many foreign tax credit computations must HiramCo
LO.3 Hart Enterprises, a domestic corporation, owns 100% of OK, Ltd., an Irish cor- poration. OK's gross income for the year is $10 million. Determine whether any of the following transactions
LO.3 Is a foreign corporation owned equally by 100 unrelated U.S. citizens consid- ered to be a controlled foreign corporation (CFC)? Explain.
LO.3 USCO owns 65% of the voting stock of LandCo, a Country X corporation. Terra, an unrelated Country Y corporation, owns the other 35% of LandCo. LandCo owns 100% of the voting stock of OceanCo, a
LO.3 Orion, Inc., a U.S. corporation, reports foreign-source income and pays for- eign taxes for the tax year as follows. Passive basket General basket Income $150,000 300,000 Taxes $13,000 150,000
LO.3 Night, Inc., a domestic corporation, earned $300,000 from foreign manufactur ing activities on which it paid $36,000 of foreign income taxes. Night's foreign sales income is taxed at a 50%
LO.3 Crank, Inc., a U.S. corporation, operates a branch sales office in Ghana. During the current year, Crank earned $200,000 in taxable income from U.S. sources and $50,000 in taxable income from
LO.3 Drake, Inc., a U.S. corporation, operates a branch sales office in Turkey. During the current year, Drake earned $500,000 in taxable income from U.S. sources and $100,000 in taxable income from
LO.3 Fleming, Inc., a domestic corporation, operates in both Canada and the United States. This year, the business generated taxable income of $400,000 from foreign sources and $300,000 from U.S.
LO.3 ABC, Inc., a domestic corporation, reports $50 million of taxable income, including $15 million of foreign-source taxable income from services ren- dered, on which ABC paid $2.5 million in
LO.3 Foldlt, a U.S. business, paid income taxes to Mexico relative to profitable sales of shipping boxes it made in that country. Can it claim a deduction for these taxes in computing U.S. taxable
LO.3 QuinnCo could not claim all of the income taxes it paid to Japan as a foreign tax credit (FTC) this year. What computational limit probably kept QuinnCo from taking its full FTC? Explain.
LO.3 USCO incurred $100,000 in interest expense for the current year. The tax book value of USCO's assets generating foreign-source income is $5 million. The tax book value of USCO's assets
LO.3 Willa, a U.S. corporation, owns the rights to a patent related to a medical device. Willa licenses the rights to use the patent to IrishCo, which uses the patent in its manufacturing facility
LO.3 Chock, a U.S. corporation, purchases inventory for resale from distributors within the United States and resells this inventory at a $1 million profit to customers outside the United States.
LO.3 Evaluate this statement: It is unfair that the United States taxes some of its citizens and residents on their worldwide income.
LO.3 BlueCo, a domestic corporation, incorporates GreenCo, a new wholly owned entity in Germany. Under both German and U.S. legal principles, this entity is a corporation. BlueCo faces a 21% U.S. tax
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