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From the e-Activity, evaluate the appropriateness of the techniques used and the common issues pursued by the IRS in corporate liq

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  • Post Date 2018-11-08T09:12:31+00:00
  • Post Category New Samples

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From the e-Activity, evaluate the appropriateness of the techniques used and the common issues pursued by the IRS in corporate liquidations and dissolutions.

Discussion: Corporate liquidations and dissolutions

INSTRUCTIONS:

"Corporate Liquidations, Taxable Acquisition Transactions, and Nontaxable Reorganizations" Please respond to the following:



Question 1 



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).





Question 2



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.





**********PLEASE FOLLOW THE INSTRUCTIONS********

This is the week 4 e-activity referenced in the questions

 

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


CONTENT:

Discussion Questions Week 4 Name Course Instructor Date Corporate liquidations and dissolutions In recognizing the gain or loss in property in liquidations, there is a need to point out that the fair market value recognized is never below the liabilities value. In many cases, problems arise when ident

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