2020 Instructions for Form 1120
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Double Taxation of Corporate Income in the United States and the OECD
Double Taxation of Corporate Income in the United States and the OECD FISCAL Taylor LaJoie Elke Asen FACT Policy Analyst Policy Analyst No. 740 Jan. 2021 Key Findings • The Tax Cuts and Jobs Act lowered the top integrated tax rate on corporate income distributed as dividends from 56.33 percent in 2017 to 47.47 percent in 2020; the OECD average is 41.6 percent. • Joe Biden’s proposal to increase the corporate income tax rate and to tax long-term capital gains and qualified dividends at ordinary income rates would increase the top integrated tax rate on distributed dividends to 62.73 percent, highest in the OECD. • Income earned in the U.S. through a pass-through business is taxed at an average top combined statutory rate of 45.9 percent. • On average, OECD countries tax corporate income distributed as dividends at 41.6 percent and capital gains derived from corporate income1 at 37.9 percent. • Double taxation of corporate income can lead to such economic distortions as reduced savings and investment, a bias towards certain business forms, and debt financing over equity financing. • Several OECD countries have integrated corporate and individual tax codes to eliminate or reduce the negative effects of double taxation on corporate The Tax Foundation is the nation’s income. leading independent tax policy research organization. Since 1937, our research, analysis, and experts have informed smarter tax policy at the federal, state, and global levels. We are a 501(c)(3) nonprofit organization. ©2021 Tax Foundation Distributed under Creative Commons CC-BY-NC 4.0 Editor, Rachel Shuster Designer, Dan Carvajal Tax Foundation 1325 G Street, NW, Suite 950 Washington, DC 20005 202.464.6200 1 In some countries, the capital gains tax rate varies by type of asset sold. -
Tax Strategies for Selling Your Company by David Boatwright and Agnes Gesiko Latham & Watkins LLP
Tax Strategies For Selling Your Company By David Boatwright and Agnes Gesiko Latham & Watkins LLP The tax consequences of an asset sale by an entity can be very different than the consequences of a sale of the outstanding equity interests in the entity, and the use of buyer equity interests as acquisition currency may produce very different tax consequences than the use of cash or other property. This article explores certain of those differences and sets forth related strategies for maximizing the seller’s after-tax cash flow from a sale transaction. Taxes on the Sale of a Business The tax law presumes that gain or loss results upon the sale or exchange of property. This gain or loss must be reported on a tax return, unless a specific exception set forth in the Internal Revenue Code (the “Code”) or the Treasury Department’s income tax regulations provide otherwise. When a transaction is taxable under applicable principles of income tax law, the seller’s taxable gain is determined by the following formula: the “amount realized” over the “adjusted tax basis” of the assets sold equals “taxable gain.” If the adjusted tax basis exceeds the amount realized, the seller has a “tax loss.” The amount realized is the amount paid by the buyer, including any debt assumed by the buyer. The adjusted tax basis of each asset sold is generally the amount originally paid for the asset, plus amounts expended to improve the asset (which were not deducted when paid), less depreciation or amortization deductions (if any) previously allowable with respect to the asset. -
October 2015 INDICTMENT and INFORMATION FORMS
INDICTMENT AND INFORMATION FORMS (REVISED) 26 U.S.C. § 7201 ............................................................................................................................ 1 Individual Taxes – Evasion (Assessment) – False Return as Only Affirmative Act .................. 1 Joint Taxes – Evasion (Assessment) – False Return as Only Affirmative Act .......................... 2 Individual Taxes – Evasion (Assessment) – False Return and Other Affirmative Acts ............. 3 Joint Taxes – Evasion (Assessment) – False Return and Other Affirmative Acts ..................... 4 Individual Taxes – Evasion (Assessment) – Spies Evasion........................................................ 5 Individual Taxes – Evasion (Payment) ....................................................................................... 7 Corporation Taxes – Evasion (Assessment) – False Return as Only Affirmative Act ............... 8 Corporation Taxes – Evasion (Assessment) – False Return and Other Affirmative Acts .......... 9 Corporation Taxes – Evasion (Assessment) – Spies Evasion ................................................... 10 Corporation Taxes – Evasion (Payment) .................................................................................. 12 Last Updated: October 2015 26 U.S.C. § 7201 Form 1 Individual Taxes – Evasion (Assessment) – False Return as Only Affirmative Act THE [GRAND JURY/UNITED STATES ATTORNEY] CHARGES: From in or about [Month Year] through in or about [Month Year], in the [_____________] District of [_____________] and elsewhere, -
Australia Overview 2018-19 Individual Income and Social Taxes
Australia Overview 2018-19 Individual Income and Social Taxes Gaining an understanding of the tax system in a new country is a critical step in addressing risks and reducing costs for companies with mobile employees. This overview summarizes key individual income and social tax compliance and tax planning considerations for companies sending employees to work in Australia. Individual income tax overview A resident of Australia is subject to Australian income tax on worldwide income at graduated tax rates that range up to 45% of taxable income. A temporary resident (defined below) is not taxed on their foreign investment income or capital gains. A non-resident of Australia is subject to Australian income tax only on Australian source income at graduated rates ranging from 32.5% to 45%. Residency A person is generally a resident of Australia if the person is domiciled in Australia or spends more than 183 days in Australia during the tax year. Domicile is the person’s permanent home (where they intend to live permanently). Individuals holding a Temporary Skills Shortage visa (i.e., subclass 482) are classified as temporary residents if they meet the following criteria: • they do not meet the definition of residency for Australian social security purposes (e.g., not a citizen, permanent resident), and • the taxpayer’s spouse is also not a resident of Australia for social security purposes. A visitor is a non-resident if they intend and actually spend less than 183 days in Australia. Available tax treaties should be considered in cases of dual-residence. Tax filings Tax Year: July 1 to June 30. -
Overview of the Tax Treatment of Corporate Debt and Equity
OVERVIEW OF THE TAX TREATMENT OF CORPORATE DEBT AND EQUITY Scheduled for a Public Hearing Before the SENATE COMMITTEE ON FINANCE on May 24, 2016 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION May 20, 2016 JCX-45-16 CONTENTS Page INTRODUCTION AND SUMMARY ........................................................................................... 1 I. PRESENT LAW ....................................................................................................................... 4 A. General Rules ...................................................................................................................... 4 1. Issuer treatment of debt and equity ............................................................................... 4 2. Holder treatment of debt and equity ............................................................................. 7 3. Acquisitions and dispositions ..................................................................................... 12 B. Distinguishing Between Debt and Equity ......................................................................... 13 1. In general .................................................................................................................... 13 2. Regulatory authority pursuant to section 385 ............................................................. 15 C. Rules to Address Stripping of U.S. Corporate Tax Base in the Case of Nontaxed Holders ............................................................................................................................. -
Beijing Subway Map
Beijing Subway Map Ming Tombs North Changping Line Changping Xishankou 十三陵景区 昌平西山口 Changping Beishaowa 昌平 北邵洼 Changping Dongguan 昌平东关 Nanshao南邵 Daoxianghulu Yongfeng Shahe University Park Line 5 稻香湖路 永丰 沙河高教园 Bei'anhe Tiantongyuan North Nanfaxin Shimen Shunyi Line 16 北安河 Tundian Shahe沙河 天通苑北 南法信 石门 顺义 Wenyanglu Yongfeng South Fengbo 温阳路 屯佃 俸伯 Line 15 永丰南 Gonghuacheng Line 8 巩华城 Houshayu后沙峪 Xibeiwang西北旺 Yuzhilu Pingxifu Tiantongyuan 育知路 平西府 天通苑 Zhuxinzhuang Hualikan花梨坎 马连洼 朱辛庄 Malianwa Huilongguan Dongdajie Tiantongyuan South Life Science Park 回龙观东大街 China International Exhibition Center Huilongguan 天通苑南 Nongda'nanlu农大南路 生命科学园 Longze Line 13 Line 14 国展 龙泽 回龙观 Lishuiqiao Sunhe Huoying霍营 立水桥 Shan’gezhuang Terminal 2 Terminal 3 Xi’erqi西二旗 善各庄 孙河 T2航站楼 T3航站楼 Anheqiao North Line 4 Yuxin育新 Lishuiqiao South 安河桥北 Qinghe 立水桥南 Maquanying Beigongmen Yuanmingyuan Park Beiyuan Xiyuan 清河 Xixiaokou西小口 Beiyuanlu North 马泉营 北宫门 西苑 圆明园 South Gate of 北苑 Laiguangying来广营 Zhiwuyuan Shangdi Yongtaizhuang永泰庄 Forest Park 北苑路北 Cuigezhuang 植物园 上地 Lincuiqiao林萃桥 森林公园南门 Datunlu East Xiangshan East Gate of Peking University Qinghuadongluxikou Wangjing West Donghuqu东湖渠 崔各庄 香山 北京大学东门 清华东路西口 Anlilu安立路 大屯路东 Chapeng 望京西 Wan’an 茶棚 Western Suburban Line 万安 Zhongguancun Wudaokou Liudaokou Beishatan Olympic Green Guanzhuang Wangjing Wangjing East 中关村 五道口 六道口 北沙滩 奥林匹克公园 关庄 望京 望京东 Yiheyuanximen Line 15 Huixinxijie Beikou Olympic Sports Center 惠新西街北口 Futong阜通 颐和园西门 Haidian Huangzhuang Zhichunlu 奥体中心 Huixinxijie Nankou Shaoyaoju 海淀黄庄 知春路 惠新西街南口 芍药居 Beitucheng Wangjing South望京南 北土城 -
State Individual Income Tax Federal Starting Points
STATE PERSONAL INCOME TAXES: FEDERAL STARTING POINTS (as of January 1, 2021) Federal Tax Base Used as Relation to Federal Starting Point to Calculate STATE Internal Revenue Code State Taxable Income ALABAMA --- --- ALASKA no state income tax --- ARIZONA 1/1/20 adjusted gross income ARKANSAS --- --- CALIFORNIA 1/1/15 adjusted gross income COLORADO Current taxable income CONNECTICUT Current adjusted gross income DELAWARE Current adjusted gross income FLORIDA no state income tax --- GEORGIA 3/27/20 adjusted gross income HAWAII 3/27/20 adjusted gross income IDAHO 1/1/20 taxable income ILLINOIS Current adjusted gross income INDIANA 1/1/20 adjusted gross income IOWA Current adjusted gross income KANSAS Current adjusted gross income KENTUCKY 12/31/18 adjusted gross income LOUISIANA Current adjusted gross income MAINE 12/31/19 adjusted gross income MARYLAND Current adjusted gross income MASSACHUSETTS 1/1/05 adjusted gross income MICHIGAN Current (a) adjusted gross income MINNESOTA 12/31/18 adjusted gross income MISSISSIPPI --- --- MISSOURI Current adjusted gross income MONTANA Current adjusted gross income NEBRASKA Current adjusted gross income NEVADA no state income tax --- NEW HAMPSHIRE on interest & dividends only --- NEW JERSEY --- --- NEW MEXICO Current adjusted gross income NEW YORK Current adjusted gross income NORTH CAROLINA 5/1/20 adjusted gross income NORTH DAKOTA Current taxable income OHIO 3/27/20 adjusted gross income OKLAHOMA Current adjusted gross income OREGON 12/31/18 taxable income PENNSYLVANIA --- --- RHODE ISLAND Current adjusted gross income SOUTH CAROLINA 12/31/19 taxable income SOUTH DAKOTA no state income tax --- TENNESSEE on interest & dividends only --- TEXAS no state income tax --- UTAH Current adjusted gross income VERMONT 12/31/19 adjusted gross income VIRGINIA 12/31/19 adjusted gross income WASHINGTON no state income tax --- WEST VIRGINIA 12/31/19 adjusted gross income WISCONSIN 12/31/17 adjusted gross income WYOMING no state income tax --- DIST. -
Journal of Accountancy Business Tax Quick Guide — Tax Year 2018
Journal of Accountancy Business tax quick guide — tax year 2018 Tear out this quick guide for use during tax season, and look for our quick guide for individual taxpayers in the January 2019 issue. C CORPORATION INCOME TAX ■■■ Credit: Maximum amount of 5.4% for contributions paid to ■■■ Taxable income of a C corporation: Taxed at a flat rate of state unemployment insurance funds. 21%. ESTIMATED TAX QUALIFIED PERSONAL SERVICE CORPORATION TAX ■■■ Corporations owing $500 or more in income tax for the ■■■ Taxable income of a qualified personal service corporation tax year must make estimated tax payments equaling the is no longer subject to tax at a flat rate of 35%, but is taxed lesser of 100% of the prior-year or current-year tax liability. at the regular corporate tax rate of 21%. Large corporations must base the last three payments on the current-year tax liability. ACCUMULATED EARNINGS TAX ■■■ Due on the 15th day of the fourth, sixth, ninth, and 12th ■■■ 20% of accumulated taxable income (in addition to regular months of the corporation’s tax year (April 15, June 15, corporate income tax). Sept. 15, and Dec. 15 for calendar-year corporations). PERSONAL HOLDING COMPANY TAX CORPORATE ALTERNATIVE MINIMUM TAX (AMT) ■■■ ■■■ 20% penalty on undistributed personal holding company Starting in 2018, the AMT no longer applies to corporations. income. ■■■ No foreign tax credit allowed against personal holding company tax. NONRESIDENT AND FOREIGN CORPORATIONS ■■■ Taxed on U.S.-source investment income at 30% (or lower under treaty). SELF-EMPLOYMENT TAX ■■■ Net income effectively connected with a U.S. -
State of Rhode Island and Providence Plantations Rhode Island Department of Revenue Division of Taxation
State of Rhode Island and Providence Plantations Rhode Island Department of Revenue Division of Taxation Public Notice of Proposed Rule-Making Pursuant to the provisions of Rhode Island General Laws (RIGL) § 42-35-3, which sets forth procedures for the adoption of rules, and in accordance with the Rhode Island Administrative Procedures Act, codified at RIGL § 42-35-1 et seq., the Rhode Island Division of Taxation hereby gives notice of its intent to promulgate a regulation regarding mandatory unitary combined reporting for purposes of the business corporation tax. The purpose of this rule making is to implement RIGL § 44-11-4.1, which involves combined reporting. The proposed regulation and concise summary of non-technical requirements and proposed new rules are available for public inspection at www.tax.ri.gov. They are also available in person at the Rhode Island Division of Taxation, or may be requested from Michael F. Canole by email at: [email protected], or by phone at: (401) 574- 8729. In the development of the proposed regulation, consideration was given to: (1) alternative approaches; (2) overlap or duplication with other statutory and regulatory provisions; and (3) whether the regulation, in and of itself, would have significant economic impact on small business. No alternative approach, duplication, or overlap was identified based upon available information. All interested parties are invited to submit written or oral comments concerning the proposed regulation by December 14, 2015 to Michael F. Canole, Rhode Island Division of Taxation, One Capitol Hill, Providence, R.I. 02908 - telephone number (401) 574- 8729 or via e-mail: [email protected]. -
2021 Tax Rates, Schedules, and Contribution Limits
2021 tax rates, schedules, and contribution limits Income tax Tax on capital gains and qualified dividends If taxable Income income But Of the Single Married/Filing jointly/Qualifying Widow(er) Tax rate is over not over The tax is amount over $0–$40,400 $0–$80,800 0% Married/Filing $0 $19,900 $0.00 + 10% $0 jointly and $19,900 $81,050 $1,990 + 12% $19,900 Over $40,400 but not Over $80,800 but not over qualifying over $445,850 $501,600 15% widow(er)s $81,050 $172,750 $9,328 + 22% $81,050 Over $445,850 Over $501,600 20% $172,750 $329,850 $29,502 + 24% $172,750 Additional 3.8% federal net investment income (NII) tax applies to individuals $329,850 $418,850 $67,206 + 32% $329,850 on the lesser of NII or modified AGI in excess of $200,000 (single) or $250,000 $418,850 $628,300 $95,686 + 35% $418,850 (married/filing jointly and qualifying widow(er)s). Also applies to any trust or $628,300 $168,993.50 + 37% $628,300 estate on the lesser of undistributed NII or AGI in excess of the dollar amount Single $0 $9,950 $0.00 + 10% $0 at which the estate/trust pays income taxes at the highest rate ($13,050). $9,950 $40,525 $995 + 12% $9,950 Kiddie tax* $40,525 $86,375 $4,664 + 22% $40,525 Child’s unearned income above $2,200 is generally subject to taxation at $86,375 $164,925 $14,751 + 24% $86,375 the parent’s marginal tax rate; unearned income above $1,100 but not $164,925 $209,425 $33,603 + 32% $164,925 more than $2,200 is taxed at the child’s tax rate. -
IRS Publication 4128, Tax Impact of Job Loss
Publication 4128 Tax Impact of Job Loss The Life Cycle Series A series of informational publications designed to educate taxpayers about the tax impact of significant life events. Publication 4128 (Rev. 5-2020) Catalog Number 35359Q Department of the Treasury Internal Revenue Service www.irs.gov Facts JOB LOSS CREATES TAX ISSUES References The Internal Revenue Service (IRS) recognizes that the loss of a job may • Publication 17, Your create new tax issues. The IRS provides the following information to Federal Income Tax (For assist displaced workers. Individuals) • Severance pay and unemployment compensation are taxable. • Publication 575, Payments for any accumulated vacation or sick time are also Pension and Annuity taxable. You should ensure that enough taxes are withheld from Income these payments or make estimated payments. See IRS Publication 17, Your Federal Income Tax, for more information. • Publication 334, Tax Guide for Small • Generally, withdrawals from your pension plan are taxable unless Businesses they are transferred to a qualified plan (such as an IRA). If you are under age 59 1⁄2, an additional tax may apply to the taxable portion of your pension. See IRS Publication 575, Pension and Annuity Income, for more information. • Job hunting and moving expenses are no longer deductible. • Some displaced workers may decide to start their own business. The IRS provides information and classes for new business owners. See IRS Publication 334, Tax Guide for Small Businesses, for more information. If you are unable to attend small business tax workshops, meetings or seminars near you, consider taking Small Business Taxes: The Virtual Workshop online as an alternative option. -
Analysis and Evaluation of the Beijing Metro Project Financing Reforms
Advances in Social Science, Education and Humanities Research, volume 291 International Conference on Management, Economics, Education, Arts and Humanities (MEEAH 2018) Analysis and Evaluation of the Beijing Metro Project Financing Reforms Haibin Zhao1,a, Bingjie Ren2,b, Ting Wang3,c 1Ministry of Transport Research Institute, Chaoyang, Beijing, China,100029; 2Beijing Urban Construction Design & Development Group Co., Limited, Xicheng, Beijing, China,100037; 3School of Civil Engineering, Beijing Jiaotong University, Haidian, Beijing, China, 100044. [email protected], [email protected], [email protected] Keywords: metro; financing; marketisation; reform Abstract. The construction and operation of a metro system are costly, and the sustainable development of a metro system is difficult using government funding alone, particularly for developing countries. The main source for metro system financing in China is, currently, government budget and bank debt. Many cities have begun to seek new ways to attract funds from finance markets, which is increasing the need for the evaluation of metro financing. This study uses Beijing as a case study that utilises various financing modes with impressive results. As participants of the financing reform, the authors collected all the relative government documents and interviewed stakeholders to accomplish this work. This article reviews the development of financing modes for the Beijing Metro system during the last four decades and analyses the role of the government in the reformed financing system within the Chinese social political environment. The study addresses the advantages and challenges of the reforms in this context. To further analyses the technical processes of typical financing modes, the public-private partnership mode of Line 4, the BT mode of Olympic Branch Line, the insurance claim mode of Line 10 and the failure of the market oriented financing for Capital Airport Line are analysed and evaluated in detail.