P Corporation acquires all of S Corporation's stock at the beginning of the current year in a
Question:
P Corporation acquires all of S Corporation's stock at the beginning of the current year in a transaction that qualifies as a Sec. 382 ownership change. P and S elect to file a consolidated tax return for the current yea r. At the time of the acquisition, S has $900,000 of pre-2018 NOLs it has not deducted. Management estimates that, because of the Sec. 382 limitation, the group will be able to use only $300,000 of the NOLs before they expire. The corporate tax rate is 21%. Determine the amount of deferred tax asset and valuation allowance the group records for S's NOL.
• P sells land to a third party for $80,000. P purchased the land from S two years ago for $70,000. S had purchased the land five years ago for $48,000.
• P's separate taxable income includes a $12,000 dividendS paid toP.
• P sold inventory to S in the previous year for which the deferred profit at the beginning of the current year is $5,000. S sells this inventory outside the consolidated group in the current year. P sells additional inventory to S in the current year, realizing a $100,000 profit. The intercompany profit on this unsold inventory is $8,000.
• The P-S group has a $20,000 consolidated NOL carryover available from the previous year. The NOL is wholly attributable to S.
• P receives $10,000 of dividends from corporations in which it owns less than 1% of the stock.
• P and S contribute cash to charities of $17,000 and $11,000, respectively.
• P lends S $150,000 early in the current year. S repays the loan later in the year. In addition, S pays P $6,000 interest at the time of repayment.
• S earns $1,600 of tax-exempt interest income, which is not included in S's $250,000 separate return taxable income.
Determine the P-S group's consolidated taxable income and consolidated tax liability for the current year. What is P's basis for the S stock at the end of the current year? Assume that P's basis for the S stock was $1.4 million at the beginning of the current year.
CorporationA Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...
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Global Taxation How Modern Taxes Conquered The World
ISBN: 9780192897572
1st Edition
Authors: Philipp Genschel, Laura Seelkopf