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15 Cards in this Set

  • Front
  • Back
What is the main goal of tax planning?
To maximize after-tax wealth while achieving non-tax goals.
Three ways to tax plan
1. Timing
2. Income shifting
3. Conversion
Time Value of Money Strategy
-________ Income
-________ Deductions
-Minimize (Minimizes Taxes)
-Maximize (Decreases income which decreases taxes)
Strategies when tax rates are constant...
-______ Income
-______ Deductions
-Defer Income (recognize in a later year because based on time value of money it's worth less at a later time so you will be paying less in taxes based on TVM)
-Accelerate Deductions (Deduct in an earlier period so that decreases the amount of income you're being taxed on... TVM)
Limitations to Tax Planning
1. Non-tax costs: penalties, need cash
2. Constructive Receipt Doctrine
3. Realization Concept
4. Assignment of Income Doctrine
5. Business Purpose Doctrine
6. Step Transaction Doctrine
7. Substance over form.
Realize versus recognize
There has been a transaction

versus

claiming it on your tax return because it is in your pocket and you are aware of it
Constructive Receipt Doctrine
You must recognize the income if it is (1) available, (2) you are aware of it and (3) there are no restrictions on spending or receiving it
Realization Concept
Taxpayer only recognizes income after its realized
Assignment of Income Doctrine
Earned income is taxed to taxpayer providing the service and income from property is taxed to individual who owns it.
Arms Length Transaction
Both parties are negotiating in good faith for themselves and it assumes that economic reality exists with this transaction.

(not considered arms-length when there is a related party)
Business Purpose Doctrine
To be deductible, the expense must be related to generating income.
Step Transaction Doctrine
If there are a series of transactions undertaken, the IRS will look at the outcome of everything in order to determine the liability.
Collapse all of the steps and look at the total.
Substance over Form.
Tax generally follows the legal form of the transaction. Debt is debt. Salary is salary.
Conversion
Conversion is changing the form of income/deduction from one type to another.

Tax law treats different types of income and deductions differently.
-Salary-->MTR
-Muni Bond Income-->No tax
Limitations on conversions
Investment expenses that are used for purposes of generating exempt income are not allowed