Virginia Corporation is a calendar-year corporation. At the beginning of 2017, i
ID: 2570971 • Letter: V
Question
Virginia Corporation is a calendar-year corporation. At the beginning of 2017, its election to be taxed as an S corporation became effective. Virginia Corp.’s balance sheet at the end of 2016 reflected the following assets (it did not have any earnings and profits from its prior years as a C corporation).
In 2017, Virginia reported business income of $51,000 (this would have been its taxable income if it were still a C corporation).
What is Virginia’s built-in gains tax in each of the following alternative scenarios?
a. During 2017, Virginia sold inventory it owned at the beginning of the year for $101,300. The basis of the inventory sold was $55,900.
b. During 2017, Virginia sold inventory it owned at the beginning of the year for $101,300. The basis of the inventory sold was $55,900. Also, assume Virginia had a net operating loss carryover of $24,400 from its time as a C corporation.
c. During 2017, Virginia sold inventory it owned at the beginning of the year for $101,300. The basis of the inventory sold was $55,900. Also assume that instead of Virginia reporting business income of $51,000 as a C corporation, its taxable income would have been $1,700.
Explanation / Answer
a. Calculation of Built in gains tax of Virginia.
Unrecognized Built in gains = FMV of assets on the first day of election year - Adjusted basis of such assets
= 442,600 - 306,200 = $136,400
Net Recognized built in gains = recognized built in gain of assets sold during the year or net income of the company as S corporation for the year whichever is less.
Recognized built in gain of assets sold during the year = Inventory Sold - Adjusted basis of such inventory
= $101,300 - 55,900 = $45,400
Net income of S corp = $51,000
Therefore, Recognized built in gains of S Corp = lower of 45,400 or $51,000 = $45,400
Net Recognized built in gains should not exceed the excess of net unrealized built in gain over recognized built in gain which is ($136,400 - 45,400) = $91,000
Since recognized built in gain of $ 45,400 is lower than than $91,000.
Recognized built in gain tax of Virginia = $45,400 x 35% (tax) = $15,890
b. Calculation of Built in gains tax in case of carry forward losses.
If there are losses to the C corp which have been carry forward to the S Corp then the same are avaiable to be deducted from Net Recognized built in gains of S corp.
UnRealized Built in gains = FMV of assets on the first day of election year - Adjusted basis of such assets
= 442,600 - 306,200 = $136,400
Net Recognized built in gains = recognized built in gain of assets sold during the year or net income of the company as S corporation for the year whichever is less.
Recognized built in gain of assets sold during the year = Inventory Sold - Adjusted basis of such inventory
= $101,300 - 55,900 = $45,400
Net income of S corp = $51,000
Therefore, Net Recognized built in gains of S Corp = lower of 45,400 or $51,000 = $45,400
Net Recognized built in gain after set off of carry forward losses = $45,400 - 24,400 = $21,000
Net Recognized built in gains should not exceed the excess of net unrealized built in gain over recognized built in gain which is ($136,400 - 21,000) = $115,400
Since recognized built in gain of $ 21,000 is lower than than $115,400
Recognized built in gain tax of Virginia = $21,000 x 35% (tax) = $7,350
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