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Homophobes everywhere 😣
How common are layoffs in big law?
This is what happens when banks pull forward all the possible deals because the market is conducive and there is nothing left for next year or two. What sucks is all the rosy expectations for future deals and massive hiring, and not a appreciation that it’s only a pull forward. Wall Street layoffs likely ahead as two-year hiring boom turns to bust https://www.cnbc.com/2022/06/27/wall-street-layoffs-are-coming-as-deals-boom-turns-to-bust-insiders-say.html?__source=iosappshare%7Ccom.apple.UIKit.activity.CopyToPasteboard
Additional Posts in Tax Bowl
Who the fk asked for the deadline extension
There’s an ITS bowl. Are you sure you’re cat 1 though? That one has an “owned on the last day in the year as an SFC” part
I thought SFC was only for transition tax year. Im pretty sure it won’t be a 1
I think it should be a short year 5471 and just financials through date of disposal. Would be great to hear from an international person on this though
Agree. Short year for the 5471 through date of disposal. OP the entity’s year end (date of disposal) falls within your filer’s tax year.
Date of disposal. If you don’t own it at year end, you can’t report it at the end of the year, right
Well, if you didn’t own it at year end, you don’t report it. Were you planning on picking up any subpart f income after you disposed of it?
I would put full year income on Sch C, 0 ending balance on schedule F. The 5471 filing is for the CFC’s annual tax period. You don’t have a change in tax year to a short year just because you disposed interest in the entity. See Sec 898. You also have potential issues under 245A because it sounds like you have an extraordinary reduction event.
Why 0 ending balance on Schedule F? that’s inconsistent with the instructions. General rule - Top of page 5471 asks for the foreign corps tax year for which the schedules are furnished. If an entity liquidates/no longer exists, the ending date at the top would be date of liquidation, and Schedule C would be for a short period, Sch F would have 0 ending balance (it liquidated) and any E&P on Sch J would be “distributed” so ending balance is 0. If the foreign corp was only sold, and still exists after date of sale, the foreign tax year does not change (so top of page 5471 would have full tax year not a short period), so Sch C would be for full tax year and Sch F would have ending balance as of year end (entity still exists remember - the balance sheet probably has an ending balance it wouldn’t be all 0 it’s not a liquidation). Sch B would have NONE since u don’t own shares at the end of the tax year, but sch A (corps shares) would still have an ending balance.
What about reporting the sale as 1248 event? New buyer can then eithet continue treating it as a CFC or DRE from acquisition date and picks up income only from that date.
They are disposing of an interest, not turning it into a DRE.
Entire interest it says above. And the acquirer if a USSH can make a 338g election and treat it as a DRE.
Agree tax director 1 but the fiction does trigger a year end which I guess is the point they’re trying to make
So it’s not actually a CFC, as the US SH has just under 50% and no other US SH. It’s not an inclusion issue, just how to report on the 5471.
General rule - Top of page 5471 asks for the foreign corps tax year for which the schedules are furnished. If an entity liquidates/no longer exists, the ending date at the top would be date of liquidation, and Schedule C would be for a short period, Sch F would have 0 ending balance (it liquidated) and any E&P on Sch J would be “distributed” so ending balance is 0. If the foreign corp was only sold, and still exists after date of sale, the foreign tax year does not change, so Sch C would be for full tax year and Sch F would have ending balance as of year end (entity still exists remember). Sch B would have NONE since u don’t own shares at the end of the tax year, but sch A (corps shares) would still have an ending balance.