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The 754 election and 743 adjustments are not applicable for SMLLCs. Per Rev Ruling 99-6 when one partner of a MMLLC purchases all of the interest in the LLC it is a deemed liquadating distribution ... See more...
The 754 election and 743 adjustments are not applicable for SMLLCs. Per Rev Ruling 99-6 when one partner of a MMLLC purchases all of the interest in the LLC it is a deemed liquadating distribution to all of the members followed by an asset purchase. In your situation you will have 50% of the assets based on the carry over basis of the LLC and 50% of the assets based on the purchase of the assets from the other partner. The partner's K-1s will report the liquidating distribution, but nothing regarding the sale.  Although it would be helpful for the selling partner to include information regarding the adjusted basis and prior depreciation as a note on the K-1 so they can properly report the sale of assets.
Yes, that video is incorrect.  At 4:55 when she said that her "tax advisor" told her to reduce the basis in the replacement vehicle by the amount of the gain on the relinquished vehicle, he was advis... See more...
Yes, that video is incorrect.  At 4:55 when she said that her "tax advisor" told her to reduce the basis in the replacement vehicle by the amount of the gain on the relinquished vehicle, he was advising her to do a 1031 exchange, which is not allowed on vehicles exchanged after 2017. In the video's example the gain would be taxable, and the basis would be the purchase price. In your situation the loss is deductible, assuming all other requirements are met. https://www.irs.gov/businesses/small-businesses-self-employed/like-kind-exchanges-real-estate-tax-tips
That would entirely depend on what code section made the interest deductible.
Sounds like their income is too high for QB.  Is this a SSTB? Do they have wages or property that may allow a deduction?
Just to be clear on your facts.  The taxpayer had physical silver bullion on deposit with a trustee.  She then moved the silver from the trustee to her personal possession.  The trustee issued her a ... See more...
Just to be clear on your facts.  The taxpayer had physical silver bullion on deposit with a trustee.  She then moved the silver from the trustee to her personal possession.  The trustee issued her a 1099-R for sending (distributing) her the silver. What does "She per her own investment into the IRA" mean.  It would truly be unusual if she put some else's investment into her IRA.  Are you trying to say that she made a non deductible contribution to her IRA? What do you mean by "the basis of her silver has gone up"? I cannot imagine how that could happen.  Did you mean the the value of the silver has gone up? "They are saying that the full amount is taxable" By they, I assume you mean the IRA trustee is reporting on the 1099-R that it is fully taxable.  I would not expect an IRA trustee to know if a taxpayer made a non deductible contribution to an IRA. Distributions from an IRA are not required to be "realized" as in sold in order to be taxable.  Merely having unfettered access is enough. Here is an article that seems relevant to your question: https://www.thetaxadviser.com/issues/2022/feb/taking-possession-coins-irs-taxable-distribution.html
C corps are required to file tax returns even with no activity.  Although, SJRCPA raises an interesting possibility of filing a consolidated return. The vagueness of our post has more to do with WH... See more...
C corps are required to file tax returns even with no activity.  Although, SJRCPA raises an interesting possibility of filing a consolidated return. The vagueness of our post has more to do with WHY, you would have a company with no activity own another company.
Your question is quite vague.  C corps are not pass through entities.  The holding company will file an 1120 reporting its activity and attributes. It may have received dividends from the operating c... See more...
Your question is quite vague.  C corps are not pass through entities.  The holding company will file an 1120 reporting its activity and attributes. It may have received dividends from the operating company, or have any number of other reporting requirements.
s179 depreciation and recapture is a separately stated line item on the K-1.  It is not rolled into box 1 of the K-1 like normal depreciation.  This is because individual shareholders are subject to ... See more...
s179 depreciation and recapture is a separately stated line item on the K-1.  It is not rolled into box 1 of the K-1 like normal depreciation.  This is because individual shareholders are subject to their own limits on deducting s179 depreciation.
The appropriate reg would be Treas. Reg. § 301.7701-3(g)(ii) (ii) Association to partnership. If an eligible entity classified as an association elects under paragraph (c)(1)(i) of this section to ... See more...
The appropriate reg would be Treas. Reg. § 301.7701-3(g)(ii) (ii) Association to partnership. If an eligible entity classified as an association elects under paragraph (c)(1)(i) of this section to be classified as a partnership, the following is deemed to occur: The association distributes all of its assets and liabilities to its shareholders in liquidation of the association, and immediately thereafter, the shareholders contribute all of the distributed assets and liabilities to a newly formed partnership. https://www.law.cornell.edu/cfr/text/26/301.7701-3
I am not an expert in ProSeries, but I do not believe that it has a "bulk sale feature".  You will either have to do it manually: https://proconnect.intuit.com/support/en-us/help-article/form-8949/... See more...
I am not an expert in ProSeries, but I do not believe that it has a "bulk sale feature".  You will either have to do it manually: https://proconnect.intuit.com/support/en-us/help-article/form-8949/entering-bulk-disposition-assets-proseries/L4SpQChUt_US_en_US?uid=llb6okkc Or each asset separately. If you are just asking about allocating the sales, there is no correct answer.  Any reasonable method would be fine.  I think personally, I would just make one manual entry for the sale of all of the assets. You may want to review the assets with the taxpayer to see if any of them were actually disposed of in prior years. If I understand you correctly you have $817k of 1245 assets with $763k of depreciation.  It sounds like you will have $346k in profit all subject to depreciation recapture.  I wouldn't use any allocation that gives a different result.
I would not recommend revoking the S election.
S to C should be tax free. S or C to partnership has tax consequences as the assets are deemed sold at FMV, which would often be a gain if they are fully depreciated.  This would be complicated by ... See more...
S to C should be tax free. S or C to partnership has tax consequences as the assets are deemed sold at FMV, which would often be a gain if they are fully depreciated.  This would be complicated by any assumption of liabilities in the liquidation as well.
That would potentially be very risky, as both the buyer's and seller's tax returns should agree on the purchase price of the assets.  Not to mention, presumably some of the price is attributable to g... See more...
That would potentially be very risky, as both the buyer's and seller's tax returns should agree on the purchase price of the assets.  Not to mention, presumably some of the price is attributable to goodwill. Section 1245 property, in particular has tax ramifications, as tax on the depreciation recapture cannot be deferred in an installment sale, and is due immediately.  Furthermore, the buyer will want to depreciate the assets, and there should be agreement on their purchase price.
Allocating the purchase price among the assets is NOT something that you should be doing.  This is something that is negotiated during sale, between the buyer and the seller.  This information is als... See more...
Allocating the purchase price among the assets is NOT something that you should be doing.  This is something that is negotiated during sale, between the buyer and the seller.  This information is also reported on Form 8594 and should be included with the tax return. This is something you need to kick back to the taxpayer to solve.  The allocation of the sale price has tax consequences for both the buyer and the seller.
You can "trick" the software by creating one asset with the consolidated totals of the fixed assets - purchase price, depreciation, etc.  An then "sell" that asset, and simply delete all the other as... See more...
You can "trick" the software by creating one asset with the consolidated totals of the fixed assets - purchase price, depreciation, etc.  An then "sell" that asset, and simply delete all the other assets. Make sure to keep the type of property the same in a consolidated entry.  1245 property is treated differently in a sale than 1250 or 1231 property.
Yes, revoking an S election would make a business a C corp. Filing a partnership election would not change your requirement to liquidate the corporation, with the associated tax consequences.  The ... See more...
Yes, revoking an S election would make a business a C corp. Filing a partnership election would not change your requirement to liquidate the corporation, with the associated tax consequences.  The IRS would still be looking for a final corp tax return.  The may be circumstances were liquidating a C corp is preferable to liquidating an S corp, but I can't think of any off the top of my head.  
That makes perfect sense as far as the CA Secretary of State is concerned.  However, the IRS will consider this to be an S-corp liquidation.  They will expect a final S-corp tax return with all of th... See more...
That makes perfect sense as far as the CA Secretary of State is concerned.  However, the IRS will consider this to be an S-corp liquidation.  They will expect a final S-corp tax return with all of the assets and liabilities distributed out at FMV to the shareholders.
Very occasionally.  Thank you for thinking of me !
You cannot reorganize back into a partnership.  It would be a corporate liquidation, and given what you said regarding basis and debt there would likely be taxes due.