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S Corporations: Built in Gain Tax 4173332A
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When an existing corporation is considering making the S corporation election, the potential corporate level built in gain tax ( IRC 1374) is frequently the most important tax cost to evaluate. Focus on describing when and how the built in gain tax is determined. Discuss topics that include the application of multiple limitations on determining the tax and the potential use of existing corporate net operating losses and tax credits. Identify and evaluate tax planning ideas and strategies.

 Export to Your Calendar 8/4/2017
When: 11:00 AM to 1:00 PM
Where: Webinar/Webcast
CALCPA
4173332A
United States
Presenter: John G. McWilliams, CPA, JD
Contact: April Deneault
801-466-10274


Online registration is available until: 8/4/2017
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Curriculums:   Business and Corporate Taxation,Financial Leadership Forum,Business and Industry

NASBA Credit Category:  Taxes

CPE Hours:  2

Description

When an existing corporation is considering making the S corporation election, the potential corporate level "built in gain tax" ( IRC 1374) is frequently the most important tax cost to evaluate. Focus on describing when and how the built in gain tax is determined. Discuss topics that include the application of multiple "limitations" on determining the tax and the potential use of existing corporate net operating losses and tax credits. Identify and evaluate tax planning ideas and strategies.

Materials are provided as an ebook for this course.



Major Subjects

  • Identification of facts that could cause the imposition of the built in gain tax
  • The calculation of the tax on "net recognized built in gain" during "recognition period"
  • The meaning of "current mandatory double tax"
  • The aggregate limitation based on "net unrealized built in gain"
  • The limitation based on the "gain" that existed at conversion
  • The importance of valuation analysis at conversion
  • The taxable income limitation
  • Using existing corporate net operating losses and tax credits
  • Tax planning ideas and strategies to minimize or avoid the tax on built in gain

Objectives

  • Identify when the built in gain tax could apply.
  • Calculate the built in gain tax including application of three "limitations."
  • Recognize the nature of the built in gain tax, "current mandatory double taxation."
  • Recognize tax planning techniques to minimize or eliminate the built in gain tax.

Level:  Overview

Designed For

CPAs and attorneys with at least two years of experience advising privately owned business.

Advanced Prep:

None.

Prerequisite

Understanding the basics of the taxation of corporations, S corporations and partnerships.

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