Question: Corporation J manufactures electrical appliances.

> NY is a New York corporation that manufactures office equipment in a factory located in New York. In which of the following cases does NY have nexus with Pennsylvania? a. NY owns two retail outlets for its products in Pennsylvania. b. NY owns no tangible

> Kantor Inc. owns 100 percent of Sub 1 (a CFC in a country with a 50 percent corporate tax) and 90 percent of Sub 2 (a CFC in a country with a 10 percent corporate tax). Kantor sells goods and services to both CFCs. Is the IRS more interested in Kantor’s

> Delta Partnership carries on business in the United States and four other countries. Explain why the ordinary income generated by the foreign business is a separately stated item on Delta’s Schedule K, Form 1065.

> Column Corporation has a subsidiary operating exclusively in Country A and a subsidiary operating exclusively in Country Z. a. Both subsidiaries were incorporated under Delaware law and are therefore U.S. corporations. Can Column use the losses from the

> Togo Inc. has a subsidiary incorporated in Country H, which does not have a corporate income tax. Which of the following activities generates subpart F income? a. The subsidiary buys woolen clothing products manufactured by a Swedish company and sells th

> Halifax Inc. operates its business in Country U through a subsidiary incorporated under Country U law. The subsidiary has never paid a dividend and has accumulated more than $10 million after-tax earnings. a. Country U has a 20 percent corporate income t

> Posse Corporation plans to form a foreign subsidiary through which to conduct a new business in Country J. Posse projects that this business will operate at a loss for several years. a. To what extent will the subsidiary’s losses generate U.S. tax saving

> EFG, an accrual basis calendar year corporation, reported $500,000 net income before tax on its financial statements prepared in accordance with GAAP. EFG’s records reveal the following information: The allowance for bad debts as of January 1 was $58,000

> Mrs. Tran and Mrs. Nutter each own a small business that averages $80,000 annual income. Each woman is in the 35 percent marginal tax bracket. Mrs. Tran has decided to incorporate her business as a taxable corporation, while Mrs. Nutter has decided to co

> Refer to the facts in the previous problem. QRT purchased $30,000 of dental equipment on credit. When QRT failed to pay its bill, the seller took it to court and won a judgment for $30,000. Discuss each owner’s personal liability for this judgment assumi

> Dr. Quinn, Dr. Rose, and Dr. Tanner are dentists who practice as equal owners of QRT Dental Services. A patient of Dr. Rose’s recently sued him for medical malpractice and was awarded a $500,000 judgment. Discuss each owner’s personal liability for this

> Mr. Eros operates an antique store located on the first floor of a four story office building owned by Mr. Eros. The top three stories are leased to business tenants. Mr. Eros is considering giving a one-third interest in both the antique store and the b

> Discuss the tax and nontax reasons why the stock in an S corporation is typically subject to a buy-sell agreement.

> How would the tax shelter potential of closely held corporations be affected by: a. An increase in the highest individual tax rate to 43 percent? b. A decrease in the preferential tax rate on individual capital gains to 5 percent? c. Repeal of the accumu

> In what way does a corporate balance sheet provide information concerning the corporation’s exposure to the accumulated earnings tax?

> Explain the logic of the tax rate for both the accumulated earnings tax and the personal holding company tax.

> Ms. Knox recently loaned $20,000 to her closely held corporation, which needed the money for working capital. She sees no reason to document the loan other than as a “loan payable—shareholder” on the corporate balance sheet. She also sees no reason for h

> When the IRS classifies a portion of a salary payment to a shareholder/employee as a constructive dividend, which party (corporation or shareholder) bears the economic burden of the tax consequences?

> Warren Company is a calendar year, cash basis firm. On December 6, 2018, Warren paid $7,200 cash to a landscape service business that maintains the lawns and gardens around Warren’s headquarters. How much of this expenditure can Warren deduct in 2018 ass

> Corporations are allowed a dividends-received deduction for dividends from other domestic, taxable corporations. How does this deduction prevent the same corporate income from potentially three levels of tax?

> The corporate form of business is characterized by free transferability of equity interests. Describe this characteristic as it applies to publicly held corporations and closely held corporations.

> To what extent does the corporate characteristic of limited liability protect shareholders employees who perform professional services for corporate clients?

> Why are certain items of income, gain, deduction, or loss separately stated on a partnership or an S corporation tax return?

> Tom, Angela, and Peter want to become co-owners of a business enterprise. Compare their personal liability for the debts incurred by the enterprise if they organize as: a. A general partnership. b. A limited partnership. c. An LLC. d. An S corporation.

> Critique the employee payroll tax on the normative standards of convenience to the taxpayer and vertical equity.

> Corporation ABC sold its interest in KK Partnership on October 9 for $150,000. KK Partnership uses a calendar year for tax purposes. Explain the reason why Corporation ABC cannot compute gain or loss realized on the date that the sale occurs.

> Mr. Yang sold his interest in a business to an unrelated purchaser for $500,000 cash. How does Mr. Yang determine his adjusted basis for purposes of computing gain or loss realized on the sale if the business is: a. A sole proprietorship? b. A partnershi

> Four years ago, Mr. Bates purchased 1,000 shares of UPF Inc. for $10,000. These shares represent a 30 percent equity interest in UPF, which is an S corporation. This year, UPF defaulted on a $120,000 unsecured debt to a major creditor. a. To what extent

> Both Mr. A and Mr. Z are sole proprietors. This year, each proprietorship generated $85,000 net cash flow from business operations. Mr. A used the cash to expand his business, while Mr. Z used the cash to make the down payment on a new home for his famil

> LSG Company is a calendar year, cash basis taxpayer. On November 1, 2018, LSG paid $9,450 cash to the janitorial service firm that cleans LSG’s administrative offices and retail stores. How much of this expenditure can LSG deduct in 2018 assuming that: a

> This year, Soya Partnership disposed of only one operating asset and recognized a $22,000 loss on the disposition. Why must Soya report this net Section 1231 loss as a separately stated item rather than deducting the loss in the computation of ordinary b

> Can a sole proprietorship be described as a pass through entity?

> In what way is the nontaxable exchange rule for partnership formations more flexible than the nontaxable exchange rule for corporate formations?

> Determine if each of the following transactions qualifies as a nontaxable exchange: a. Firm A exchanges a 2 percent interest in MG Partnership for a 10 percent interest in KLS Partnership. b. Mr. B exchanges investment land for common stock in RV Inc. Im

> When a taxpayer transfers appreciated property to a corporation in exchange for newly issued stock and the exchange is nontaxable, the gain deferred on the exchange actually doubles. Can you explain this?

> If a corporation engages in a nontaxable exchange of assets, could the transaction result in a book/tax difference? Is this difference a permanent or a temporary difference?

> Explain the difference between a substituted basis in an asset and a carryover basis in an asset.

> Four years ago, Company PJ acquired 1,000 acres of undeveloped land. On the date of the exchange, the land’s FMV was $700,000. During the past four years, the land appreciated in value by $600,000; a recent appraisal indicated that it is worth $1.3 milli

> Two years ago, Firm OP bought a tract of land for $600,000, paying $50,000 down and borrowing the balance of the purchase price from a commercial lender. The land is the collateral for OP’s debt. To date, OP has not repaid any of the loan. a. If the debt

> Mrs. Carly called her accountant with a question. She is planning to sell nine acres of land for $380,000 cash. She purchased the land eight years ago for $195,000. She asked her accountant if her gain on sale would be a capital gain, and his answer was,

> NC Company, a retail hardware store, began business in August and elected a calendar year for tax purposes. From August through December, NC paid $319,000 for inventory to stock the store. According to a physical inventory count on December 31, NC had $6

> Both Corporation A and Corporation Z have business goodwill worth approximately $1 million. The goodwill is a capital asset to Corporation A and a Section 1231 asset to Corporation Z. Can you explain this apparently inconsistent tax characterization?

> Distinguish between a firm’s tax basis in an asset and its equity in that asset.

> Under what circumstances would a taxpayer elect not to use the installment sale method of reporting gain?

> Under what circumstances could a taxpayer have an amount realized on the disposition of an asset without any inflow of cash or property?

> Why is Section 1250 recapture inapplicable to sales of realty subject to MACRS depreciation?

> Why do both corporate and non corporate taxpayers prefer capital gains to ordinary income? Why is the preference stronger for non corporate taxpayers?

> Identify four possible differences in the computation of depreciation expense for financial statement purposes and MACRS depreciation.

> Identify the tax and nontax issues that firms must consider in adopting the LIFO method of accounting for inventories.

> On February 1, Mr. B purchased a business from Mr. and Mrs. S for a lump-sum price of $750,000. The business included the following balance sheet assets. Appraised FMV Accounts receivable $ …………………………….27,600  Inventory ……………………………………………….195,000  Offic

> Brillo Company uses the calendar year and the cash method of accounting. On December 29, 2018, Brillo made the following cash payments. To what extent can Brillo deduct the payment in 2018? a. $50,000 for a two-year office lease beginning on February 1,

> Discuss the strengths and weaknesses of the tax rule providing for 15-year amortization of the cost of business acquisition intangibles.

> Discuss the reasons why the Section 179 election is more valuable to small firms than to large firms.

> The manager of Firm Z, a new business that anticipates a steady growth in profits over the next decade, must decide between the cash method and the accrual method as the overall method for tax purposes. She understands that the difference between the two

> If a corporation purchases insurance on the life of its chief executive officer and the corporation is named the policy beneficiary, the premium payments are nondeductible. If the officer’s spouse and children are named as beneficiaries, the premium paym

> For many years, Mr. K, the president of KJ Inc., took the corporation’s most important clients golfing at The Links Golf Club several times a year. However, after the tax law was amended to disallow a deduction for business entertainment, Mr. K and his c

> Lester Inc. owns 55 percent of the outstanding stock of Marvin Corporation. The two corporations engage in numerous intercompany transactions that must be accounted for on both their financial statements and their tax returns. Discuss the circumstances i

> Discuss the choice of a taxable year for the following businesses: a. Retail plant and garden center. b. French bakery. c. Chimney cleaning business. d. Moving and transport business. e. Software consulting business.

> Describe the contrasting treatment of prepaid income under GAAP and under the tax law, and explain how each treatment reflects a different principle of conservatism.

> Firms generally prefer to engage in transactions that create assets instead of liabilities. However, firms prefer transactions generating deferred tax liabilities to transactions generating deferred tax assets. Can you explain this apparent contradiction

> Why do tax preferences often result in differences between book income and taxable income? Would a book/tax difference from a tax preference be a permanent difference or a temporary difference? Which type of difference is more valuable in NPV terms?

> Nello Company owed $23,400 overdue rent to its landlord, Bonview Inc. Because Nello is a desirable tenant, Bonview agreed to settle the overdue account for a $15,000 cash payment from Nello. Both Nello and Bonview are accrual basis taxpayers. a. What is

> Firm A expects to receive a $25,000 item of income in August and a second $25,000 item of income in December. The firm could delay the receipt of both items until January. As a result, it would defer the payment of tax on $50,000 income for one full year

> Why do income shifts and deduction shifts usually occur between taxpayers who are related parties?

> Compare the potential tax savings of an income shift from one entity to another if the entities are subject to: a. A progressive income tax system with rates from 5 percent to 19 percent. b. A progressive income tax system with rates from 10 percent to 5

> Assume that the U.S. Congress replaces the current individual and corporate income tax rate structures with a proportionate rate that applies to both types of taxpayers. Discuss the effect of this change in the federal law on tax strategies based on: a.

> Mr. T is considering a strategy to defer $10,000 income for five years with no significant opportunity cost. Discuss the strategic implications of the following independent assumptions: a. Mr. T is age 24. He graduated from law school last month and acce

> In June, Congress enacts legislation that increases income tax rates for all entities effective for the next calendar year. a. Why might such legislation result in an increase in federal tax revenues for this year? b. In what way would this legislation c

> Identify the reasons why managers should evaluate the flexibility of a tax planning strategy before implementing the strategy.

> For each of the following situations, discuss whether the individual is engaging in tax avoidance or tax evasion. a. Mr. L performed minor construction work for a number of people who paid him in cash. Because Mr. L knows that there is almost no chance t

> In the U.S. system of criminal justice, a person is innocent until proven guilty. Does this general rule apply to disputes between a taxpayer and the IRS?

> Which type of tax law provision should be more stable and less uncertain as to its future application: a provision relating to the proper measurement of taxable income or a provision designed to encourage individual taxpayers to engage in a certain econo

> Company K has a 30 percent marginal tax rate and uses a 7 percent discount rate to compute NPV. The company started a venture that will yield the following before-tax cash flows: year 0, $12,000; year 1, $21,000; year 2, $24,000; year 3, $17,600. a. If t

> Use a 5 percent discount rate to compute the NPV of each of the following series of cash receipts and payments: a. $6,200 received now (year 0), $1,890 paid in year 3, and $4,000 paid in year 5. b. $10,000 paid now (year 0), $12,690 paid in year 2, and $

> Explain the relationship between the degree of financial risk associated with future cash flows and the discount rate used to compute NPV.

> Corporation P owns 85 percent of the outstanding stock of Corporation R. This year, employees of Corporation R performed extensive management services for Corporation P. In return for the services, Corporation P paid a $250,000 fee to Corporation R, whic

> In each of the following cases, discuss how the taxpayers might respond to a tax rate increase in a manner consistent with the income effect. a. Mr. E earns $32,000 a year as an employee, and Mrs. E doesn’t work. b. Mr. F earns $22,000 a year as an emplo

> Corporation R and Corporation T conduct business in Jurisdiction Q. The corporations’ financial records for last year show the following: Jurisdiction Q decided to enact a tax on corporations conducting business within its jurisdictio

> Jurisdiction W has decided to enact a personal income tax on its residents. Policymakers are considering the following alternatives: a. No tax on income up to $35,000, and a 15 percent tax on all income in excess of $35,000. b. A 10 percent tax on all in

> The federal income tax is criticized as being both inequitable across individuals and overly complicated. Discuss why equity and simplicity can be considered conflicting tax policy goals.

> Jurisdiction E spends approximately $7 million each winter on snow removal. The jurisdiction is considering adding a new income tax provision that would allow people to deduct the cost of snow removal equipment purchased during the year. a. Does this pro

> Jurisdiction R and Jurisdiction S both impose a personal income tax on their residents. Under Jurisdiction R’s system, employers are required to withhold income tax from their employees’ paychecks and remit the tax to the government. Jurisdiction S’s sys

> The Internal Revenue Code and Treasury regulations are two major sources of federal tax law. Differentiate between the Code and the regulations in terms of their relative weight of authority.

> One way for the federal government to increase tax revenues would be to enact either a VAT or a national retail sales tax. The U.S. sales tax could be collected in the same manner and at the same time as state and local sales taxes. Which tax would be le

> Firm M and Firm N are related parties. For the past several years, Firm M’s marginal tax rate has been 30 percent, and Firm N’s marginal tax rate has been 21 percent. Firm M is evaluating a transaction that will generate $10,000 income in each of the nex

> Differentiate between a property tax and a transfer tax.

> Does the federal income tax or the federal payroll tax have the broader tax base?

> Both the federal government and many states impose so-called sin taxes: excise taxes levied on the retail sale of liquor and cigarettes. Discuss the reasons why sales of these particular items make a good tax base.

> Discuss the tax policy implications of the saying “an old tax is a good tax.”

> The federal government levies a gift tax on the value of property that people give away during their life and an estate tax on the value of property that people transfer at death. From the government’s perspective, which tax is more convenient?

> What evidence suggests that the federal tax system receives a low grade when evaluated on the standard of sufficiency?

> What nonmonetary incentives affect the amount of time and energy people devote to income-generating activities?

> Ms. V resides in a jurisdiction with a 35 percent income tax. Ms. V has $40,000 that she could invest in bonds paying 8 percent annual interest. She is also considering spending the $40,000 on a new luxury automobile. Ms. V is having a hard time deciding

> In each of the following cases, discuss how the taxpayers might respond to a tax rate increase in a manner consistent with the substitution effect. a. Mr. H earns $195,000 a year as a salaried employee, and Mrs. H doesn’t work. b. Mr. J earns $195,000 a

> Mr. and Mrs. K pay $18,000 annual tuition to a private school for their three children. They also pay $2,300 property tax on their personal residence to support the local public school system. Should Mr. and Mrs. K be exempt from this property tax?

> BPK Inc. and OPK Inc. are owned by the same family. BPK’s marginal tax rate is 21 percent, and OPK’s marginal tax rate is 32 percent. BPK is about to incur a $72,000 deductible expense that would benefit both corporations. OPK could obtain the same mutua

> Mr. P owns a residential apartment complex in a suburban area. This year, the local jurisdiction increased the property tax rate on the apartment complex. To offset this additional cost, Mr. P decreased the amount he usually spends on maintaining the ext

> Custer County is considering raising revenues by imposing a $25 fee on couples who obtain a marriage license within the county. Does this fee meet the definition of a transaction-based tax?

> LN Consulting is a calendar year, cash basis unincorporated business. The business is not required to provide audited financial statements to any external user. LN’s accounting records show the following. LN’s record

> Croyden is a calendar year, accrual basis corporation. Mr. and Mrs. Croyden (cash basis taxpayers) are the sole corporate shareholders. Mr. Croyden is president of the corporation, and Mrs. Croyden is vice president. Croyden’s financial