Question
Use a flat corporate tax rate of 21% for all problems. For individuals assume a tax rate of 15% for all dividends and capital gains.
Use a flat corporate tax rate of 21% for all problems. For individuals assume a tax rate of 15% for all dividends and capital gains. Assume there is no Alternative Minimum Tax for these problems. Assume that all entities are US domestic corporations, taxed under Subchapter C of the IRC unless otherwise noted. the internal revenue code.
Shadow Corporation had two shareholders, Daniel and Tiger. Their ownership and basis in the company at | ||||
January 1, 2021 was as follows: | ||||
# Shares Owned | Total Basis | Date Acquired | ||
Daniel | 30 | 30,000 | 1/1/2015 | |
Tiger | 70 | 60,000 | 1/1/2014 |
On January 1, 2021, Shadow Corporation had accumulated earnings and profits of 100,000
Shadow Corporation had a loss in the current year, resulting in negative current earnings and profits of (100,000)
Shadow made the following cash distributions during 2021 (note these are the total distributions, | ||
paid proportionately to each shareholder, in accordance with their ownership). | ||
01-February | 50,000 | |
01-July | 50,000 | |
01-October | 50,000 |
On August 1, 2021 Tiger sold all his shares to Leo for 80,000
a. What are the tax consequences to Daniel as a result of the July 1 distribution?
b. What are the tax consequences to Tiger as a result of the August 1 stock sale?
c. What are the tax consequences to Leo as result of the October 1 distribution?
d. What are Shadow Corporation's earnings and profits at January 1, 2022?
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