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2008 CCH Comp Topics Ch15

2008 CCH Comp Topics Ch15 - Chapter 15 Corporate...

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Chapter 15 Corporate Nonliquidating Distributions ©2007 CCH. All Rights Reserved. 4025 W. Peterson Ave. Chicago, IL 60646-6085 1 800 248 3248 www.CCHGroup.com
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CCH Federal Taxation Chapter 15 Exhibits Chapter 15, Exhibit Contents A 1. Effect of Operations on Owners—Comparison Among Entities 2. Effect of Nonstock Distributions on Owners—Comparison Among Entities 3. Effect of Nonstock Distributions on Entities—Comparison Among Entities 4. Effect of Taxable Stock Distributions on Shareholders 5. Effect of Identical, Nontaxable Stock Distributions on Shareholders 6. Effect of Nonidentical, Nontaxable Stock Distributions on Shareholders 7. Effect of Stock Redemptions on Shareholders 8. Effect of Stock Redemptions on Corporations 9. Effect of Complete Liquidations on Shareholders 10. Effect of Complete Liquidations on Corporations
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CCH Federal Taxation Chapter 15 Exhibits Chapter 15, Exhibit Contents B 11. Nonstock Distributions—Effect on Shareholders 12. Earnings and Profits of C Corporations 13. Nonstock Distributions—Effect on Corporation 14. Nonstock Distributions—Examples 15. Stock Distributions 16. Redemptions (Including Partial Liquidations)—Overview 17. Redemptions (Including Partial Liquidations)—Tax Effect on Shareholders 18. Redemptions (Including Partial Liquidations)—Example on Shareholder Effect 19. Redemptions (Including Partial Liquidations)—Tax Effect on Corporations 20. Redemptions (Including Partial Liquidations)—Example on Corporate Effect
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CCH Federal Taxation Chapter 15, Exhibit 1a Effect of Operations on Owners— Comparison Among Entities Operating Item C Corps S Corps Partnerships Undistributed income No tax to shareholder Current tax Current tax Current losses: General No deduction to shareholder Current deduction Current deduction Limit N/A Outside basis at risk Outside basis at risk Character conduit No Yes (Code Sec. 1366(b)) Yes
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CCH Federal Taxation Chapter 15, Exhibit 1b Operating Item C Corps S Corps Partnerships Owner’s basis: General Constant (unaffected by corporate activity) Adjusted annually Adjusted annually Effect of entity debt None None (neither basis nor AAA affected; only at- risk amount) Outside basis AND at-risk amount affected (Code Sec. 752) Effect of Operations on Owners— Comparison Among Entities
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CCH Federal Taxation Effect of Nonstock Distributions on Owners— Comparison Among Entities C and S Corporations Partnerships How is “amount distributed” to owners computed? FMV of all property received by shareholder Corporate debt assumed by shareholder Cash + Debt relief [i.e., for purposes of determining gain, only cash + debt relief are subject to capital gains. Other property received by a partner is tax- free.] Chapter 15, Exhibit 2a
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CCH Federal Taxation C and S Corporations Partnerships What is the owners’ tax treatment for the “amount distributed?” C Corps.
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