Description
"Corporate Liquidations, Taxable Acquisition Transactions, and Nontaxable Reorganizations" Please respond to the following:
- 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).
e-Activity: Go to the Tax Almanac Website, located at http://www.taxalmanac.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.
- 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.
Explanation & Answer
please find the attached file. i look forward to working with you again. good bye
Running Head: CORPORATE LIQUIDATIONS
Corporate Liquidations and Taxable Acquisition Transactions
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CORPORATE LIQUIDATIONS
Corporate Liquidations and Taxable Acquisition Transactions
Part I
Corporate liquidations and dissolutions are processes that involve the application and the
use of various techniques. They also involve a number of common issues that are pursued by the
IRS. For instance, the liquidation of the corporation income is a challenge. There are many
problems that involve the reporting of income by the liquidating corporation. This is because of
the issue of held substantial accounts receivable by a cash-basis corporations. This would
therefore be similar to the professional corporations.
The other issue is the assignment of the income doctrine. The doctrine states that upon
liquidation the right of receiving income must not be distributed to the shareholders. There is
again the case where the billing by the corporation made to the customers for the rendered
serv...
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