Assignment 1: Client LetterImagine that you are a Certified Public Accountant (CPA) with a new client who needs an opinion on the most advantageous capital structure of a new corporation. Your client formed the corporation in question to provide technology to the medical profession to facilitate compliance with the Health Insurance Portability and Accountability Act (HIPAA). Your client is very excited because of the ability to secure several significant contracts with sufficient capital.
Use the Internet and Strayer databases to research the advantages and disadvantages of debt for capital formation versus equity for capital formation of a corporation. Prepare a formal letter to the client using the six (6) step tax research process in Chapter 1 and demonstrated in Appendix A of your textbook as a guide.
Write a one to two 600- 650 page letter in which you:
1. Compare the tax advantages of debt versus equity capital formation of the corporation for the client.
2. Recommend to the client whether he / she should use debt or equity for capital formation of the new corporation, based on your research. Provide a rationale for the response.
3. Use the six (6) step tax research process, Provided below to record your research for communications to the client.
Week 4 Assignment 2
Assignment 2 :Constructive Dividends, Redemptions, and Related Party Losses
Suppose you are a CPA hired to represent a client that is currently under examination by the IRS. The client is the president and 95% shareholder of a building supply sales and warehousing business. He also owns 50% of the stock of a construction company. The remaining 50% of the stock of the construction company is owned by the client’s son. The client has received a Notice of Proposed Adjustments (NPA) on three (3) significant issues related to the building supply business for the years under examination. The issues identified in the NPA are unreasonable compensation, stock redemptions, and a rental loss. Additional facts regarding the issues are reflected below:
· Unreasonable compensation: The taxpayer receives a salary of $10 million composed of a $5 million base salary plus 5% of gross receipts not to exceed $5 million. The total gross receipts of the building supply business are $300 million. The NPA by the IRS disallows the salary based on 5% of gross receipts as a constructive dividend
· Stock redemptions: During the audit period, the construction company redeemed 50% of the outstanding stock owned by the client and 50% of the stock owned by the client’s son, leaving each with the same ownership percentage of 50%. The redemption was treated as a distribution under Section 301 of the IRC by the IRS.
· Rental loss: The rental loss results from a building leased to the construction company owned by the client and his son.
Write a three page paper in which you:
1. Based on your research and the facts stated in the scenario, prepare a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal.
2. Create a tax plan for the future redemption of the client’s stock owned in the construction company that will not be taxed according to Section 301 of the IRC.
3. Propose a strategy for the client to receive similar amounts in compensation in the future and avoid the taxation as a constructive dividend.
4. Use the six (6) step tax research process to record your research for communications to the client.
Use the Internet and databases to research the rules and income tax laws regarding unreasonable compensation, stock redemptions treated as dividends and related party losses. Be sure to use the six (6) step tax research process in Chapter 1 and demonstrated in Appendix A of your textbook as a guide for your written response.
ACC565 Week 7 Assignment 3
Assignment 3: Reorganizations and Consolidated Tax Returns
Due Week 7 and worth 250 points
Suppose you are a CPA, and you have a corporate client that has been operating for several years. The company is considering expansion through reorganizations. The company currently has two (2) subsidiaries acquired through Type B reorganizations. The client has asked you for tax advice on the benefit of a Type A, C, or D reorganization over a Type B reorganization. Additional facts regarding the issues are reflected below.
- The company currently files a consolidated income tax return with the two (2) subsidiaries acquired through a Type B reorganization.
- ABC Corporation, a subsidiary targeted by the client for takeover, has substantial net operating losses.
- XYZ Corporation and BB Corporation will be acquired as subsidiaries in the next six (6) months.
Use the Internet and Strayer databases to research the rules and income tax laws regarding Types A, B, C, and D reorganizations and consolidated tax returns. Be sure to use the six (6) step tax research process in Chapter 1 and demonstrated in Appendix A of your textbook as a guide for your written response.
Write a four to six (4-6) page paper in which you:
- Compare the long-term tax benefits and advantages of each type of reorganization, and recommend the type of reorganization that will be most beneficial to the client.
- Suggest the type of reorganization the client should use for the ABC Corporation based on your research. Justify the response.
- Propose a taxable acquisition structure for the client’s planned acquisitions over a nontaxable reorganization. Assess the value of a taxable transaction over a nontaxable reorganization for the client.
- Examine the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and provide a recommendation to your client. Support the recommendation with applicable research.
- Create a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group.
- Use the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.
Your assignment must follow these formatting requirements:
- Be typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides; citations and references must follow APA or school-specific format. Check with your professor for any additional instructions.
- Include a cover page containing the title of the assignment, the student’s name, the professor’s name, the course title, and the date. The cover page and the reference page are not included in the required assignment page length.
The specific course learning outcomes associated with this assignment are:
- Prepare client, internal, and administrative documents that appropriately convey the results of tax research and planning.
- Evaluate tax-planning strategies related to liquidating distributions, acquisitions, and reorganizations.
- Create an approach to tax research that results in credible and current resources.
- Research and analyze tax issues regarding consolidated tax returns.
- Use technology and information resources to research issues in organizational tax research and planning.
- Write clearly and concisely about organizational tax research and planning using proper writing mechanics.
Assignment 4: Tax-Planning Client Letter on Irrevocable Trusts, Gift Tax, and Estate Tax
Due Week 10 and worth 150 points
Suppose you are a CPA, and your client has requested advice regarding establishing an irrevocable trust for his two (2) grandchildren. He wants the income from the trust paid to the children for 20 years and the principal distributed to the children at the end of 20 years.
Use the Internet and Strayer databases to research the rules regarding irrevocable trusts, gift tax, and estate tax. Be sure to use the six (6) step tax research process in Chapter 1 and demonstrated in Appendix A of your textbook as a guide for your written response.
Write a one to two (1-2) page letter in which you:
- Analyze the effect of an irrevocable trust on the gift tax and future estate taxes.
- Suggest other significant alternatives that the client could use both to reduce estate tax and to maximize potential advantages of the payment of gift taxes on transfers of property.
- Use the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.
Your assignment must follow these formatting requirements:
- Be typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides; citations and references must follow APA or school-specific format. Check with your professor for any additional instructions.
- Include a cover page containing the title of the assignment, the student’s name, the professor’s name, the course title, and the date. The cover page and the reference page are not included in the required assignment page length.
The specific course learning outcomes associated with this assignment are:
- Prepare client, internal, and administrative documents that appropriately convey the results of tax research and planning.
- Create an approach to tax research that results in credible and current resources.
- Analyze tax issues regarding the gift tax and the estate tax.
- Analyze tax issues regarding trusts and estates.
- Use technology and information resources to research issues in organizational tax research and planning.
- Write clearly and concisely about organizational tax research and planning using proper writing mechanics.
Parent and Subsidiary Corporations have filed calendar-year consolidated tax returns for several years. Parent Corporation uses the cash method of accounting while Subsidiary Corporation uses the accrual method of accounting. If Parent lends Subsidiary money,
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A consolidated return's tax liability is owed by
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Albert contributes a Sec. 1231 asset to a partnership on June 1 of this year in exchange for a 10% partnership interest. He had purchased the asset on March 1, 2002. His holding period for the partnership interest begins
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Meg and Abby are equal partners in the AM Partnership, which earns $40,000 ordinary income, $6,000 long-term capital gain (LTCG), and $2,000 Sec. 1231 loss during the current year. What is the amount and character of income that must be reported on Abby's tax return for this year's partnership operations?
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| | $20,000 ordinary income, $3,000 LTCG, $1,000 Sec. 1231 loss |
| | $19,000 ordinary income, $3,000 LTCG |
| | $23,000 ordinary income, $1,000 Sec. 1231 loss |
| | $22,000 ordinary income |
Allen contributed land, which was being held for sale to Allen's customers, to a partnership in exchange for a 20% interest. The partnership uses the land in its business for three years and then sells the property. When the property was contributed, it had a basis in Allen's hands of $500,000 and an FMV of $600,000. The partnership sells the land for $700,000. The gain reported by the partnership is
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The AB Partnership has a machine with an FMV of $25,000 and a basis of $20,000. The partnership has taken an $8,000 depreciation on the machine. The unrealized receivable related to the machine is
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The definition of "inventory" for purposes of Sec. 751 includes
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An S corporation is not treated as a corporate taxpayer with respect to which one of the following fringe benefits?
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Which one of the following individuals or entities is ineligible to be an S corporation shareholder?
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The recognition period for the built-in gains tax extends for how many years after the S election takes effect?
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In 1998, Delores made taxable gifts to her son of property with an FMV of $200,000. In the current year when Delores dies, the property is worth $800,000. The amount included in Delores's estate tax base because of the 1998 gift is
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Hu makes a gift of his home to a local homeless shelter (a 501(c)(3) charity). Hu will retain his home for 10 years, after which the homeless shelter will take possession. The value of Hu's 10-year interest is $30,000 and the remainder interest is valued at $120,000. Which of the following statements is correct?
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Gordon died on January 1 and by his will left land with an adjusted basis of $60,000 and an FMV of $100,000 to Becky. Becky disclaims the property on December 31 of the year of death, when the land was still worth $100,000. Becky has made a gift (before the annual gift tax exclusion) of
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In 2012, Paul transfers $1,000,000 to a trust benefiting his three children. As trustee, he has the power to determine the amount of distributions each year. Paul dies in the current year when the trust has a value of $1,200,000. How much of the trust's value is included in Paul's estate?
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Following are the fair market values of Wilma's assets at her date of death:
Personal effects and jewelry | $150,000 |
Land which Wilma bought and held as a joint tenant with right of survivorship with her sister | 800,000 |
The executor of Wilma's estate did not elect the alternate valuation date. The amount includible in Wilma's gross estate is
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Four years ago, David gave land to Mike that he purchased for $70,000, which is presently worth $100,000. Three years ago, Mike exchanged the land (then worth $150,000) along with a $100,000 cash contribution made by David for a new piece of land worth $250,000. The new land is titled with David and Mike as joint tenants with the right of survivorship. When Mike dies this year, the land is worth $300,000. Mike's estate will include
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Administration expenses incurred by an estate
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The conduit approach for fiduciary income tax means
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Which of the following activities is protected by accountant-client privilege?
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Terry files his return on March 31. The return shows taxes of $6,000, and Terry pays this entire amount when he files his return. By what time must he file a claim of refund?
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Gerald requests an extension for filing his last year's individual income tax return. His tax liability is $10,000, of which $8,000 was withheld, leaving a balance due of $2,000 when he files on August 1 of the current year. His penalty for failure to pay the tax on time is
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U.S. citizen Barry is a bona fide resident of a foreign country for all of 2013. Barry uses a calendar year as his tax year and receives $158,000 in salary and allowances from his employer. Included in the $158,000 is a $25,000 housing allowance. Barry's housing costs are $30,000. The base housing amount for the current year is $15,616. What amount related to his housing can Barry exclude on his Form 2555?
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U.S. citizen who has a calendar tax year establishes a tax home and residence in a foreign country and qualifies for the foreign-earned income exclusion for 60 days in 2010; 365 days in 2011; and 60 days this year, 2012. The maximum earned income exclusion for this year is?
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What are the carryback and carryforward periods for the foreign tax credit?
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Charitable contributions made by a fiduciary
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Administration expenses incurred by an estate
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Solution: strayer acc565 all assignments and final exam [ week 2 , week 4, week 7 and week 10 assignments ]