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27 Cards in this Set
- Front
- Back
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Once formed a corporation must make certain elections
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selecting tax year
selecting accounting methods |
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s corporations must generally use ___for its choice of tax year.
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calendar year
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form that you use to request approval for accouning period change
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1128
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Wich conditions mst be met
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corporation files short period tax return for the year of change and annualizes invome when computing
files 12 month returns subsequently closes its books as of the last day of the short period if generates NOL may not carry back can carry forward must not have changed tax years within last 48 months must not have an interst in a pass through entity Cannot be an S corporation, tzx exempt org or other spec corp |
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coporation not required to use accrual method if it meets ___ of the follwing conditions
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qualified family farming operation
a qualified personal service corporation if prior three year recipts do not total 3mil s corporations TWO |
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CORPORATE CAPITAL GAINS ARE TAXED AT THE ---- RATE
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REGULAR CORPORATE TAX RATE
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corporate NOL is
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the excess of its deduction over its income
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Passive losses apply to ___ and not to_____
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individuals, partners, s corp shareholders, closely held C corporations, and PSCs
do not apply to widely held C corp |
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are considered to be business related and are deductible in full
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casualty losses
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if a corporation incurs a net captial loss it treats it how
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it cannot deduct the net loss in the current year
a corporations capital losses can only offset captial gains. |
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a corporation must carry back a net captial loss as___ and offset captial gains in the __
If the loss is not completely absorbed as a carrkyback, the remainder |
a short term captial loss to the tree previous tax year
earliest year possible carries over as a short term capital loss for five years |
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section 291 staes
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if a taxpayer sells sec 1250
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a corporation must carry back a net captial loss as___ and offset captial gains in the __
If the loss is not completely absorbed as a carrkyback, the remainder |
a short term captial loss to the tree previous tax year
earliest year possible carries over as a short term capital loss for five years |
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section 291 staes
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if a taxpayer sells sec 1250
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SOURCES OF TAX LAW
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LEGISLATION
INTERNAL REVENUE CODE TREASURY REGULATIONS ADMINISTRATIVE PRONOUNCEMENTS JUDICIAL DECISIONS TAX TREATIES OTHER |
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LEGISLATIVE PROCESS
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WAYS AND MEANS COMMITTEE
FULL HOUSE SENATE FINANCE COMMITTEE FULL SENATE CONFERENCE COMMITTEE FULL HOUSE AND SENATE PRESIDENT SIGNS OR VETOES |
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INTERNAL REVENUE CODE
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TITLE 26 OF US CODE
ORGANIZATION TITLE SUBTITLE CHAPTER SUBCHAPTER PART SUBPART SECTION |
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TREASURY REGULATIONS
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AUTHORITY DELEGATED TO IRS
TYPES PROPOSED: NO WEIGHT TEMPORARY IMMEDIATE GUIDANCE SAME AUTHORITY AS FINAL REGS. FINAL INTERPRETIVE INTERPRET RELATED CODE SECTION LESS AUTHORITY THAN IRC LEGISLATIVE ALMOST SAME AUTHORITY AS IRC LEGISLATIVE REENACTMENT DOCTRINE |
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ADMINISTRATIVE PRONOUNCEMENTS
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REVENUE RULINGS
MORE SPECIFIC THAN REGS. LESS AUTHORITY THAN REGS. REVENUE PROCEDURES IRS GUIDANCE ON PROCEDURAL MATTERS |
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PRIVATE LETTER RULINGS
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RESPONSES TO PARTICULAR TP QUESTIONS
ONLY AUTHORITY FOR SPECIFIC TP |
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JUDICIAL DECISIONS
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OVERVIEW OF FEDERAL COURT SYST.
US TAX COURT US DISTRICT COURT US COURT OF FEDERAL CLAIMS US COURT OF APPEALS (CIRCUITS) US SUPREME COURT PRECIDENTIAL VALUE OF VARIOUS DECISIONS |
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OVERVIEW OF COURTS
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SUPREME COURT
COURT OF APPEALS FOR GEOGRAPHICAL JURISDICTION US DISTRICT COURT US TAX COURT COURT OF APPEALS FOR FEDERAL CIRCUIT US COURT OF FEDERAL CLAIMS |
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TAX COURT
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DON’T PAY BEFORE LITIGATING
NO JURY TRIAL REGULAR AND MEMORANDUM DECISIONS SMALL CASES PROCEDURE ACQUIESCENCE POLICY REGULAR DECISIONS FIRST TIME COURT HEARS |
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MEMORANDUM DECISIONS
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FACTUAL VARIATIONS OF PRIOR CASES
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SMALL CASE PROCEDURE
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CASES LESS THAN 50K ELIGIBLE
LESS FORMAL THAN REGULAR TAX COURT |
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US DISTRICT COURTS
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CAN HAVE JURY TRIAL
MUST PAY DEFICIENCY FIRST UNREPORTED DECISIONS OCCUR DECISIONS NOT OFFICIALLY REPORTED PUBLISHED BY RIA AND CCH |
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COURT OF CLAIMS
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NO JURY TRIAL
MUST PAY DEFICIENCY FIRST APPEALABLE DECISIONS TO FEDERAL CIRCUIT |
