Question 1: Fundamental Principles of Federal Tax Law
Analyze and apply the fundamental principles of federal tax law to various business entities.
Scenario: ABC Consulting LLC, a partnership firm, is considering converting to a C corporation. Discuss the federal tax implications of this conversion. Include in your discussion the tax treatment of partnership income versus corporate income, potential benefits, and drawbacks of the conversion, and the impact on the partners/shareholders.
Question 2: Tax Treatment of Corporate Income, Expenses, and Deductions
Evaluate the tax treatment of corporate income, expenses, and deductions.
Scenario: XYZ Corporation incurred the following expenses in the tax year: research and development costs, employee salaries, charitable contributions, and fines for regulatory violations. Explain how each of these expenses is treated for tax purposes. Include relevant tax code sections and any limitations or special rules that apply.
Question 3: Corporate Organization and Capital Structure Decisions
Assess the tax implications of corporate organization and capital structure decisions.
Scenario: DEF Corporation is planning to issue both debt and equity to raise capital for expansion. Discuss the tax implications of using debt versus equity financing. Include considerations such as interest deductibility, dividend payments, and the impact on the corporation’s taxable income.
Question 4: Corporate Earnings and Profit Distributions
Analyze the tax consequences of corporate earnings and profit distributions.
Scenario: GHI Corporation has significant retained earnings and is considering paying dividends to its shareholders. Analyze the tax consequences for both the corporation and its shareholders. Include in your analysis the concept of double taxation and any relevant tax planning strategies to mitigate the tax burden.
Question 5: Corporate Redemptions and Liquidations
Examine the tax effects of corporate redemptions and liquidations.
Scenario: JKL Corporation is undergoing a partial liquidation and plans to redeem a portion of its outstanding shares. Examine the tax implications of this redemption for the corporation and the shareholders. Discuss the difference between treating the redemption as a sale versus a dividend.
Question 6: Corporate Reorganizations and Restructuring
Evaluate different types of corporate reorganizations and their tax implications.
Scenario: MNO Corporation is merging with PQR Corporation. Discuss the tax implications of this merger, considering both tax-free and taxable reorganization options. Include in your discussion the requirements for a tax-free reorganization and the potential benefits and drawbacks of each option.
Question 7: Consolidated Returns and Multistate Taxation