As you’ve undoubtedly learned by now, you often have to focus on the details in tax law
/in Feeds /by Munene davidAs you’ve undoubtedly learned by now, you often have to focus on the details in tax law, and the rules
surrounding corporate formation are no exception to this rule. We know that a corporation is generally seen as a separate taxable entity from its shareholders. As a result, corporate formations, which involve transfers of property between the shareholders and the corporation, would be taxable to both the corporation and the shareholders. It’s no surprise that this result would often discourage corporate formation. Congress remedied this particular problem by enacting Section 351, and your text details how this provision operates.
Did Congress craft a provision that allows corporations and their shareholders to avoid taxation on these transactions permanently, or did it have something else in mind? Support your answer!
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Relatively recent revisions to the Code have modified the tax treatment of dividends
/in Feeds /by Munene davidRelatively recent revisions to the Code have modified the tax treatment of dividends. Put your Internet research
skills to use and tell me about these changes and their consequences.
In particular, tell me
(1) what dividends are, as defined by the Code;
(2) what the recent changes effectively do (and how it was different from the prior approach to the taxation of dividends); and
(3) what the changes sought to achieve (in other words, why was the change made?).
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Emerald Corporation, a calendar year C corporation, was formed and began operations on July 1, 2014.
/in Feeds /by Munene davidEmerald Corporation, a calendar year C corporation, was formed and began operations on July 1, 2014. The
following expenses were incurred during the first tax year (July 1 through December 31, 2014) of operations:
Expenses of temporary directors and of organizational meetings | $9,000 |
Fee paid to the state of incorporation | $1,000 |
Accounting services incident to organization | $2,500 |
Legal services for drafting the corporate charter and bylaws | $3,500 |
Expenses incident to the printing and sale of stock certificates | $4,000 |
Assuming a Section 248 election, what is the Emerald’s deduction for organizational expenditures for 2014?
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