Questions from Federal Taxation

Q: IrishCo, a manufacturing corporation resident in Ireland, distributes products through

IrishCo, a manufacturing corporation resident in Ireland, distributes products through a U.S. office. Current-year taxable income from such sales in the United States is $12 million. IrishCo’s U.S. of...

Q: The BCD Partnership plans to distribute cash of $20,000

The BCD Partnership plans to distribute cash of $20,000 to partner Brad at the end of the tax year. The partnership reported a loss for the year, and Brad’s share of the loss is $10,000. At the beginn...

Q: Jasmine Gregory is a 20% member in Sparrow Properties LLC,

Jasmine Gregory is a 20% member in Sparrow Properties LLC, which is a lessor of residential rental property. Her share of the LLC’s losses for the current year is $100,000. Immediately before consider...

Q: Four GRRLs Partnership is owned by four girlfriends. Lacy holds a

Four GRRLs Partnership is owned by four girlfriends. Lacy holds a 40% interest; each of the others owns 20%. Lacy sells investment property to the partnership for its fair market value of $200,000 (La...

Q: Gil’s outside basis in his interest in the GO Partnership is $

Gil’s outside basis in his interest in the GO Partnership is $100,000. In a proportionate current distribution, the partnership distributes to him cash of $30,000, inventory (fair market value of $40,...

Q: In general, what are the tax consequences of a § 338

In general, what are the tax consequences of a § 338 election?

Q: When Teri’s outside basis in the TMF Partnership is $80,

When Teri’s outside basis in the TMF Partnership is $80,000, the partnership distributes to her $30,000 of cash, an account receivable (fair market value of $60,000, inside basis to the partnership of...

Q: The stock of Quail Corporation is held as follows: 85%

The stock of Quail Corporation is held as follows: 85% by Pheasant Corporation and 15% by Gisela, an individual. Quail Corporation is liquidated in December of the current year pursuant to a plan adop...

Q: Save the Squirrels, Inc., a § 501(c)(

Save the Squirrels, Inc., a § 501(c)(3) organization that feeds the squirrels in municipal parks, receives a $250,000 contribution from Animal Feed, Inc., a corporation that sells animal feed. In exch...

Q: In each of the following independent cases in which the partnership owns

In each of the following independent cases in which the partnership owns no hot assets, indicate: • Whether the partner recognizes gain or loss. • Whether the partnership recognizes gain or loss. • Th...