Corporate Liquidations, Taxable Acquisition Transactions, homework help
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“Corporate Liquidations, Taxable Acquisition
Transactions, and Nontaxable Reorganizations” Please respond to the
following:
- From
the e-Activity, evaluate the appropriateness of the techniques used and
the common issues pursued by the IRS in corporate liquidations and
dissolutions. Create an argument to defend the client if the IRS pursues
the assignment of income doctrine or the clear reflection of income
doctrine on a cash-basis corporation, as reflected in the Examining
Officers Guide (EOG).
e-Activity: Go to the Tax Almanac Website, located
at http://www.taxalmanac.org/index.php/Tax_Research_Resources,
or use the Internet and Strayer databases to research Section 336 of the IRC,
Treasury Regulations 1.336, and related judicial decisions. Focus on the
appropriateness of the techniques used and the common issues pursued by the IRS
in corporate liquidations and dissolutions. Be prepared to discuss.
- IRC
Section 338 allows a deemed sale election generating immediate taxation to
the target corporation and a stepped-up or stepped-down basis to the price
paid by the acquiring corporation for the target corporation stock plus
liabilities on the deemed sale. Examine at least one (1) benefit of a Section
IRC 338 liquidation election for a target corporation. Create a situation
which demonstrates a favorable IRC Section 338 liquidation election for a
target corporation.
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