The course focuses on the relevant provisions of Subchapter C of the Internal Revenue Code, as well as related Treasury Regulations and judicial opinions, governing corporate formation, operations, distributions, and liquidation. federal income taxation of corporations and their shareholders.Practical in-class study problems facilitate self-discovery of technical tax knowledge along with the development of a variety of professional skills and attitudes.In this module, you will learn about corporate non-liquidating distributions.First, earnings and profits (E&P) will be discussed, and you will learn how to calculate E&P.Next, you will analyze the treatment of cash distributions followed by property distributions.You will then cover the treatment of stock distributions.Finally, treatment of constructive dividends and qualified dividends will be explored.
Understand the tax consequences of corporate redemptions to the distributee shareholder and the redeeming corporation Understand the transactions that trigger Sec.382 loss limitations and determine how to apply the limitations in a non consolidated and in a consolidated context.Also, determine and apply the tax implications of computing consolidated taxable income and filing consolidated tax returns.The primary difference between C corporations and S corporations is that C corporations are taxed twice on earned income: : once at the corporate level when the income is earned, and again at the shareholder level when the income is distributed.The rules governing distributions from C corporations differ from the rules that apply to distributions from S corporations.To the extent that a distribution is made from the corporation’s earnings and profits, it is taxed to the shareholder as a dividend. The portion of the distribution that is not considered a dividend is applied first to reduce the shareholder’s basis in the corporation’s stock. Any remaining portion is treated as gain from the sale or exchange of property (capital gain). Important Note: If a shareholder assumes a liability or takes property subject to a liability, the amount of the distribution is reduced by the amount of the liability. Special rules also apply at the corporate level. Special rules apply to distributions to a shareholder in exchange for the shareholder’s stock (redemptions).