Accumulated Earnings Tax - CPA Regulation (REG)

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Question

Presto Corp., a calendar year domestic C corporation, is not a personal holding company. For purposes of the accumulated earnings tax, Presto has accumulated taxable income for Year 3. Which step(s) can Presto take to eliminate or reduce any Year 3 accumulated earnings tax?

I. Demonstrate that the “reasonable needs” of its business require the retention of all or part of the Year 3 accumulated taxable income.

II. Pay dividends by April 15, Year 4.

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Answer

To minimize the impact of the accumulated earnings tax, a corporation can argue on the basis of “reasonable needs” of business before the IRS, and provide a specific, definite, and feasible plan for the use of such retained earnings. Additionally, dividends paid by the corporate tax return deadline which reduce accumulated earnings will also reduce or eliminate the tax on those earnings.

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