Question

In: Accounting

Cordeio, Inc. is a controlled foreign corporation (CFC) for the entire tax year. Yancy Company, a...

Cordeio, Inc. is a controlled foreign corporation (CFC) for the entire tax year. Yancy Company, a U.S. corporation, owns 70% of Cordeio's one class of stock for the entire year. Subpart F income is $470,000, and no distributions have been made during the year. Both entities use the calendar tax year.

Assume a 365-day year and not a leap year. Round any division to six decimal places and use in subsequent computations. Round your final answers to the nearest dollar.

a. What amount does Yancy include in gross income as a constructive dividend for the tax year?
$

b. Assume that Cordeio is a CFC until March 1 of the calendar tax year. What amount does Yancy include in gross income as a constructive dividend for the tax year?
$

Solutions

Expert Solution

It is a concept in U.S. taxation in which various distributions to shareholders are not labeled as dividends but are still considered dividends by the IRS and taxed as such. Constructive dividends are most commonly found in companies in which the employees are also the shareholders. You can think of a constructive dividend as an undeclared dividend by the company that involves the use of corporate assets.

a. What amount does Yancy include in gross income as a constructive dividend for the tax year?

Yancy Company, a U.S. corporation, owns 70% of Cordeio, Inc. one class of stock for the entire year. Subpart F income is $470,000, and no distributions have been made during the year.

The amount that Vancy include in gross income as a constructive dividend for the tax year
= 70% * $470,000 = $329000

b. Assume that Cordeio is a CFC until March 1 of the calendar tax year. What amount does Yancy include in gross income as a constructive dividend for the tax year?

Assume that Cordeio is a CFC until March 1 of the calendar tax year. also assume that it is not a leap year, therefore time till March 1 = 31
(January) + 28 (February) = 59 days
The amount that Vancy include in gross income as a constructive dividend for the tax year
= 70% * $470,000 * (59 days /365 days)
= 70% * $470000 * 0.1616
= $653166.4 or $53166 (rounding off to nearest dollar)


Related Solutions

Egg Inc is a corporation that earns $300,000 for tax year 2019. The marginal individual tax...
Egg Inc is a corporation that earns $300,000 for tax year 2019. The marginal individual tax rate applicable to the entity’s shareholder is 37% on ordinary income and 20% on dividends. The corporate tax rate is 21% and the S corporation shareholders receive the full 20% of qualified business income deduction. All after tax income is distributed currently. Please compute the S corporation and C corporations’ available after-tax earnings.
Did you ever want to be a corporation? Can US shareholders for CFC purposes be individuals?...
Did you ever want to be a corporation? Can US shareholders for CFC purposes be individuals? If so, then does mean they are taxed on their sec. 951(a) subpart F inclusions just like US Shareholders that are DCs? Are US Shareholder that are DCs able to use sec. 960 for sec. 951A GILTI? The answers to these questions are obviously yes. So, if you were a US shareholder of a CFC, then would you want to be treated as a...
Simms Corp. controlled four domestic subsidiaries and one foreign subsidiary. Prior to the current year, Simms...
Simms Corp. controlled four domestic subsidiaries and one foreign subsidiary. Prior to the current year, Simms Corp. had excluded the foreign subsidiary from consolidation. During the current year, the foreign subsidiary was included in the financial statements. How should this change in accounting entity be reflected in the financial statements?
Corporate Tax Payable with M&P Zenox Ltd. is a Canadian controlled private corporation (CCPC) with all...
Corporate Tax Payable with M&P Zenox Ltd. is a Canadian controlled private corporation (CCPC) with all of its operations located in Saskatchewan. Sharon Zenox owns 100 percent of the outstanding shares of this Company. At the beginning of 2017, the Company has a non-capital loss carry forward of $54,000. The Company intends to deduct this carry forward during the year. For the 2017 taxation year, Zenox has Net Income For Tax Purposes of $625,000. This is made up of $523,000...
Jill lived and worked in North Carolina for the entire 2013 tax year. Her adjusted gross...
Jill lived and worked in North Carolina for the entire 2013 tax year. Her adjusted gross income was $81,000 and she qualifies for the standard deduction of $3000 and exemption of $2000. Use the following 2011-2013 NC tax rate schedule (taken from http://www.dor.state.nc.us/taxes/individual/rates.html) to calculate her 2013 NC tax. If your filing status is single; and taxable income is more than: but not over: your tax is: $ 0 $12,750 6% OF THE NC TAXABLE INCOME AMOUNT ON FORM D-400...
According to Publication 514, Foreign Tax Credit for Individuals, a taxpayer who claims the Foreign Tax...
According to Publication 514, Foreign Tax Credit for Individuals, a taxpayer who claims the Foreign Tax credit, can still claim an itemized deduction of any foreign credit that is not allowed as a credit if any except which of the following are true (1) Foreign tax was paid or accrued to a county that supports acts of international terrorism (2) the taxpayer participated in or cooperated with an international boycott (3) Taxes were paid in connection with the purchase or...
ABC, Inc., a domestic corporation, owns 100% of HighTax, a foreign corporation. HighTax has $50,000,000 of...
ABC, Inc., a domestic corporation, owns 100% of HighTax, a foreign corporation. HighTax has $50,000,000 of undistributed E & P, all of which is attributable to general limitation income, and $30,000,000 of foreign income taxes paid. HighTax distributes a $5,000,000 dividend to ABC. The dividend, which is subject to a 5% foreign withholding tax, is ABC's only item of income during the year. The U.S. tax rate is 35%. a. ABC's deemed-paid taxes on the dividends are $_____, and the...
Raptor Inc. (RI) is a Canadian-controlled private corporation and has provided you with the following selected...
Raptor Inc. (RI) is a Canadian-controlled private corporation and has provided you with the following selected information related to its 2019 taxation year ended December 31, 2019. RI Inc. did not have taxable capital in excess of $10,000,000 in 2018. Canadian manufacturing profits - 451,500 $ Canadian retail business income - 50,000 Taxable capital gains(non-active) - 4,500 Interest income: Canadian long-term bonds - 40,000 Interest on overdue accounts receivable - 5,000 Dividend income: From taxable Canadian corporations(eligible dividend) (RI owns...
Part I And Part IV Refundable Taxes Warron Inc. is a Canadian controlled private corporation. It...
Part I And Part IV Refundable Taxes Warron Inc. is a Canadian controlled private corporation. It has a December 31 year end. The following information relates to its 2017 taxation year. 1.    At the end of 2016, the Company’s Refundable Dividend Tax On Hand balance was $19,400. The 2016 dividend refund was $7,100. 2.    Warron Inc. paid taxable dividends of $53,250 during the year. 3.    Warron Inc. owns 35 percent of the voting shares of Delux Inc., another CCPC with...
IN THE DISPUTE OF US-TAX TREATMENT FOR “FOREIGN SALES CORPORATION “ US DEFEND ITS POLICY AS FOLLOWS:
  1-IN THE DISPUTE OF US-TAX TREATMENT FOR “FOREIGN SALES CORPORATION “ US DEFEND ITS POLICY AS FOLLOWS: US APPLIES THE WORLDWIDE TAXATION SYSTEM. EXPORTERS IN US ARE IN DISADVANTAGEOUS POSITION COMPARED WITH EXPORTERS IN COUNTRIES WITH TERRITORIAL TAXATION SYSTEM, WHERE OVERSEAS INCOME IS NOT SUBJECT TO TAXATION OF HOME COUNTRY IF THE PANEL SUPPORTS EU’S POSITION, IT IMPLIES ALL THE MEMBERS WITH TERRITORIAL TAXATION ARE IN VIOLATION OF WTO RULES. HOW DID THE PANEL ANALYZE THE ISSUE? 2-SEVERAL “exception...
ADVERTISEMENT
ADVERTISEMENT
ADVERTISEMENT