Questions from Federal Taxation

Q: Discuss situations in which the partnership entity form might be more advantageous

Discuss situations in which the partnership entity form might be more advantageous (or disadvantageous) than operating as a Subchapter C or S corporation.

Q: Wong, Inc., a § 501(c)(3)

Wong, Inc., a § 501(c)(3) organization, is a private foundation with a tax year that ends on May 31. Gross receipts for the fiscal year are $180,000, and the related expenses are $160,000. a. Is the e...

Q: Partin, Inc., a foreign subsidiary of Jones, Inc.,

Partin, Inc., a foreign subsidiary of Jones, Inc., a U.S. corporation, reports pretax income of 200,000 euros for the current year. Partin accrues 60,000 euros in foreign taxes on this income. The ave...

Q: In terms of the rules applying to a § 332 parent-

In terms of the rules applying to a § 332 parent-subsidiary liquidation, comment on each of the following: a. The parent corporation’s ownership interest in the subsidiary. b. The period of time in wh...

Q: How does a proportionate current distribution of cash from a partnership to

How does a proportionate current distribution of cash from a partnership to a partner compare with one from a Subchapter C corporation to a shareholder?

Q: Tobias is a 50% member in Solomon LLC, which does

Tobias is a 50% member in Solomon LLC, which does not invest in real estate. On January 1, Tobias’s adjusted basis for his LLC interest is $130,000, and his at-risk amount is $105,000. His share of lo...

Q: What is a partnership agreement? What types of provisions does it

What is a partnership agreement? What types of provisions does it include?

Q: Your client, Royal Corporation, generates significant interest income from its

Your client, Royal Corporation, generates significant interest income from its working capital liquid investments. Write a memo for the tax research file, discussing the planning opportunities present...

Q: Beckett Corporation realized $800,000 of taxable income from the

Beckett Corporation realized $800,000 of taxable income from the sales of its products in States A and B. Beckett’s activities establish nexus for income tax purposes in both states....

Q: Last year, Pink Corporation acquired land and securities in a §

Last year, Pink Corporation acquired land and securities in a § 351 tax-free exchange. On the date of the transfer, the land had a basis of $720,000 and a fair market value of $1 million, and the secu...