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A detailed overview of the taxation of corporate distributions to shareholders, including the distinction between dividend income and return of capital, the calculation of current and accumulated earnings and profits, the tax treatment of stock dividends and stock splits, and the rules governing stock redemptions. It covers key concepts such as the double taxation of distributed corporate income, the adjustments made to taxable income to determine earnings and profits, the order of distributions, the tax basis of property received as a dividend, and the requirements for a redemption to be treated as an exchange rather than a dividend. The document also discusses the constructive ownership rules that can impact the tax treatment of redemptions. Overall, this comprehensive chapter exam covers a critical area of corporate taxation that is essential for understanding the taxation of business entities and their shareholders.
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When a corporation distributes property to shareholders in their capacity as shareholders, the shareholders will characterize the distribution as either _________________________________ or a __________________________________. - ✔✔dividend income ; return of capital Shareholders include the portion characterized as _______________________________________ in their gross income. In contrast, a return of capital is considered not income, but rather a ____________________________________ in the shareholder's tax basis in their stock. - ✔✔dividend income ; reduction If the return of capital ____________________ the tax basis in the stock, then the excess distribution is taxed as a _________________________ from the sale of the shares. - ✔✔exceeds ; capital gain Corporate distributions of "property" usually take the form of cash, but distributions can also consist of other tangible or intangible property. Special rules apply when a corporation distributes its own stock, in the form of __________________________________________, to its shareholders. - ✔✔stock dividends
A _____________________________ is any distribution of property made by a corporation to its shareholders out of its earnings and profits account. - ✔✔dividend Corporations must keep two separate E&P accounts: one for the current year, called
__, and one for undistributed earnings and profits accumulated in all prior years, called
__________________. - ✔✔current earnings and profits ; accumulated earnings and profits. A year-to-year calculation maintained by a corporation to determine if a distribution is a dividend. Earnings and profits are computed for the current year by adjusting taxable income to make it more closely resemble economic income. - ✔✔current earnings and profits Undistributed earnings and profits from years prior to the current year.
Distributions are designated as dividends in the following order: - ✔✔1. Distributions are dividends up to the balance of current E&P.
In a nontaxable stock distribution, each shareholder allocates a portion of their tax basis from the stock on which the distribution was issued to the newly issued stock based on the relative _____________________________________________ of the stock. - ✔✔fair market value In the case of a simple distribution of common stock or a stock split where the stock distributed is identical to the stock from which the distributions is made, the new per-share tax basis is the __________________________________ divided by the total number of ____________________________________________. - ✔✔original tax basis ; shares held A ______________________________________ is an acquisition by a corporation of its stock from a shareholder in exchange for property, whether the stock so acquired cancelled, retired, or held as treasury stock. - ✔✔stock redemption Stock redemptions take the form of an exchange in which shareholders give up their ___________________ in the corporation for _______________________________, usually ___________________. - ✔✔stock ; property ; cash If the form of the transaction is respected, shareholders compute ________________ or _______________ by comparing the amount realized with their tax basis in the stock exchange. - ✔✔gain ; loss
shareholder for purposes of determining whether the shareholder has met the ______________________________________ ownership tests. - ✔✔shareholder ; change-in-stock The purpose of the attribution rules it to ________________ shareholders from __________________________ stock ownership to either family members who have similar economic interests or entities controlled by the shareholder to avoid have a ___________________________________________ characterized as a dividend. - ✔✔prevent ; dispersing ; stock redemption Owners or beneficiaries of entities can be ______________________to own shares of stock owned by the entity itself. - ✔✔deemed Shareholders are deemed to own a pro rata share of their corporation's stock holdings, but only if they own at least _________________________ of the value of the corporation's stock. - ✔✔50 percent If the tax law characterizes the distribution as a __________________________, the corporation may not deduct the amount paid in computing its taxable income. In addition, the shareholder must include ______________________________ of the dividend received in gross income. - ✔✔dividend ; gross amount The nondeductibility of the distribution to the shareholder, creates ______________________________ of the corporation's income, first
at the corporate level and then at the shareholder level. - ✔✔double taxation The corporate tax rate is significantly ______________ than the maximum individual tax rate. - ✔✔lower