CORPORATE TAXATION (ACCTG 833) TU 2:30 C208 Fall 2007 INSTRUCTOR: Dr. Richard L. Ott OFFICE: CALVIN 109 (PHONE--532-5639) OFFICE HOURS: TU 11-12 and anytime by appointment TEXTS: Anderson, Pope, and Kramer Federal Taxation of Corporations 2008 COURSE OBJECTIVES: The objectives of this course are for students to : (1) learn and understand the basic principles of federal income taxation of corporations; (2) improve their research and critical thinking skills; (3) enrich their written and oral communication skills; and (4) enhance their teambuilding skills. Students will read and discuss the Internal Revenue Code, relevant court cases, and the textbook to achieve the first objective. Specific topics include: Choice of business entity Corporate formations Taxable years and tax accounting methods Differences between book earnings and taxable income Current and deferred tax provisions Corporate tax payment requirements Corporate tax credits and other incentives Corporate alternative minimum tax S corporate income allocations Built-in taxes on S corporations S corporation shareholder basis adjustments Shareholder-level loss limitations C corporation distributions Penalty taxes on corporate accumulations S corporation distributions Controlled groups of corporations Consolidated corporate tax returns Basis adjustments to subsidiaries’ stocks Foreign tax credits Sourcing of income and deductions Branches vs foreign subsidiaries Subpart F income Transfer pricing issues Sales and exchanges of corporate stock Stock redemptions Loss limitations Corporate liquidations Once the students know the tax law, they will be expected to exhibit a higher level of cognitive reasoning through the use of cases, tax planning, and testing. I am establishing a goal for us of reaching the evaluation/synthesis stage of Bloom's Taxonomy. Written and oral communication skills will be emphasized through presentations and participation in class. Group work will be used to encourage team-building skills. Department of Accounting Learning Objectives The Department of Accounting's curriculum is designed to correspond to levels of Bloom's Taxonomy of Cognitive Objectives. Lower levels of Bloom's Taxonomy (knowledge, comprehension, and application) are emphasized in the lower division courses while the higher cognitive objectives (analysis, synthesis and evaluation) are stressed in upper division/graduate courses. This does not imply that some of the higher cognitive objectives are not reached in the lower division courses, just that it is not emphasized. Synthesis and Evaluation are the levels of Bloom's Taxonomy this course emphasizes. In addition, the accounting program lists ten learning objectives for its students. These objectives are listed below with the appropriate emphasis in this course. 1. Technical Knowledge--High 2. Critical Thinking--High 3. Ethical Standards--High 4. Teamwork--High 5. Diversity—NA (Not Addressed) 6. Accounting Origins—NA 7. Oral Communication--High 8. Written Communication--High 9. Computer Skills--High 10. Lifelong Learning--High Class Organization EXAMS: Three exams will be administered during the semester--two during the semester and a final. The final will be comprehensive. TEACHING METHOD: Although this course will utilize the lecture method to some degree, the seminar method will be used predominately. Class participation and preparation are extremely important in the seminar method. You are expected to have completed assignments prior to class and should be prepared to discuss them. The satisfaction, knowledge, and skills you acquire in this class are a function of how much you commit yourself to the course. You must be prepared to participate in each class to succeed in this course. GRADE SUMMARY: 2 exams @ 100 points each= Daily quizzes Tax Return Research Cases and Presentation Comprehensive final Total 200 60 50 100 100 510 GRADING SCALE: A= 90% B= 80% C= 70% D= 60% F= <60% QUIZZES: Eight quizzes will be given during the semester. Quizzes are worth 10 points each and the lowest two quizzes will be dropped. RESEARCH CASES AND PRESENTATION: You will be assigned to a group. Each group will research a particular area of interest in Corporate Taxation, identify key issues that have been litigated, summarize the literature and court cases in a written report. The group will also make a presentation to the class on the paper. MAKE-UP EXAMS: Make-up exams will be given only to students with valid excuses. Failure to prepare adequately for the exam or a need to leave campus early for a holiday is not considered valid excuses. Approval for taking a make-up exam must be obtained prior to the time of the original exam. An exception to this policy will be made only if it can be shown by the student that it was impossible to comply with it. In the event that grade records and/or exams are unavailable for final grade determination purposes at the end of the semester, the entire grade for the course will be determined by the score on the comprehensive final exam. Kansas State University Undergraduate Honor System: Kansas State University instituted an undergraduate honor system in 1999. The basic difference between the new honor system and the old one related to academic dishonesty is that students now hold majority representation on hearing panels. This significant change gives students ownership in the honor system and a reason to protect the integrity of our university. I expect you will do all academic work in this class. any academic work unless specifically approve by me. Do not collaborate on On all assignments, exams, or other course work undertaken by students, the following pledge is implied, whether or not it is stated: "On my honor, as a student, I have neither given nor received unauthorized aid on this academic work." Please visit the Honor System web page for more information at: http://www.ksu.edu/honor. Any student with a disability who needs an accommodation or other assistance should make an appointment to speak with me as soon as possible. September 24, 2007--last day to drop a course without a "W" being recorded. October 26, 2007--last day to drop a course. The assignment schedule is tentative and subject to change. Assignment Schedule (Tentative) Fall 2007 DATE WORK T Aug 21 Introduction--Tax Research Review U 23 Tax Research Review Anderson and Pope (A&P) Ch 1 Review your notes from tax research T 28 Review of Property Transactions Examples 1-3 U 30 Review of Property Transactions Examples 4-7 T Sept 4 Corporate Formations and Capital Structure U 6 Corporate Formations and Capital Structure T 11 Corporate Formations and Capital Structure U 13 Corporate Formations and Capital Structure T 18 Exam 1 Quiz 1 A&P Ch 2 Examples 1 and 2 A&P Ch 2 A&P Ch 2 Debt v Equity Presentation A&P Problems (PR) 2-34, 2-35, 2-43, 2-45, 2-53, 2-54, 2-55 §351 Presentation Quiz 2 U 20 Sales and Use Tax Deloitte & Touche Charee McWilliams and Cynthia McKinney Wisconsin Dept. of Revenue v. William Wrigley, Jr. Inc. 505 U.S. 214 S.C. (1992); Quill Corp. v. North Dakota 504 U.S. 298 S.C. (1992) T 25 Corporate Income Tax Quiz 3 A&P Ch 3 U Corporate Income Tax A&P Ch 3 27 T Oct 2 Corporate Income Tax A&P Ch 3 PR 3-38, 3-40, 3-43, 3-44, 3-47, 3-51 U 4 Control Groups A&P Ch 3-52, 3-53 Control Groups Presentation T 9 Corporate Income Tax Corporate Nonliquidating Distributions Quiz 4 A&P Ch 3 A&P Ch 4 U 11 Corporate Nonliquidating Distributions Tax return due--Pr 3-63 Using CCH software T 16 Corporate Nonliquidating Distributions Stock Redemptions Ch 4 PR 4-28, 4-30, 4Nonliquidating Distributions Presentation U 18 Stock Redemptions Ch 4 PR 4-35, 4-36, 4-44, 4-46, 4-51 Stock Redemption Presentation Quiz 5 T 23 Other Corporate Levies AMT Personal Holding Co. Tax Accumulated Earnings Tax A&P Ch 5 PR 5-45, 5-46, 5-48 Examples 1-6 U 28 Other Corporate Levies AMT A&P Ch 5 PR 5-54, 5-58, 5-61 PHC Presentation AET Presentation Personal Holding Co. Tax Accumulated Earnings Tax T 30 Exam 2 Chapters 3, 4, 5 and SALT U Nov 1 International Tax (Dan Friederich Grant Thornton) A&P Ch 16 T 6 International Tax (Dan Friederich Grant Thornton) A&P Ch 16 PR 16-35, 16-36, 16-37 U 8 S Corporations Quiz 6 A&P Ch 11 T 13 S Corporations A&P Ch 11 PR 11-36, 11-37, 11-41, 11-43 U 15 S Corporations A&P Ch 11 PR 11-49, 11-52, 11-53 S Corp Presentation T 20 Consolidated Tax Return Quiz 7 A&P Ch 8 U 22 Thanksgiving Holiday T 27 Consolidated Tax Return A&P Ch 8 U 29 Consolidated Tax Return Presentation—Corporate Acquisitions and Reorganizations A&P Ch 8 PR 8-32, 8-39, 8-48, 8-49, 8-50 T Dec 4 Corporate Liquidations U 6 F 12 Corporate Liquidations Quiz 8 A&P Ch 6 Examples 1-4 A&P Ch 6 PR 6-38, 6-39 6-40, 6-43, 6-45 Examples 5-7 Comprehensive Final 9:40-11:30 Suggested Areas of Research §351 Debt vs. Equity Control Groups Corporate Nonliquidating Distributions Stock Redemptions Personal Holding Co. Tax Accumulated Earnings Tax S Corporations Corporate Acquisitions and Reorganizations The above topics will be assigned on a first come-first serve basis. You can choose an area not on the list with my approval. You should identify the key issues that have been litigated in your area and summarize the major court cases. A group paper is due at the time you make a presentation to the class. See syllabus for due dates. The paper is weighted 75% and the presentation 25%. Presentations should not exceed 15 minutes. See me if this time limit is a problem.