Hard1 markMultiple Choice
Area III: Entity Tax PlanningTCPEntity TaxS Corporation

CPA · Question 26 · Area III: Entity Tax Planning

An S Corporation was formerly a C Corporation. At the time of conversion, it had $100,000 of Net Unrealized Built-in Gains (NUBIG). In Year 3 (within the 5-year recognition period), the S Corp sells an asset with a basis of $20,000 and FMV of $50,000. The asset was held at conversion with a built-in gain of $25,000. The S Corp's taxable income for Year 3 (calculated as if it were a C Corp) is $15,000. What is the amount of Built-in Gains (BIG) Tax liability (assume 21% rate)?

Answer options:

A.

$6,300 (21% of $30,000)

B.

$5,250 (21% of $25,000)

C.

$3,150 (21% of $15,000)

D.

$0

How to approach this question

BIG Tax Base is the LEAST of: 1. Recognized Built-in Gain ($25k). 2. Taxable Income if C Corp ($15k). 3. Remaining NUBIG ($100k). Lesser is $15k. Multiply by 21%.

Full Answer

C.$3,150 (21% of $15,000)✓ Correct
C
IRC §1374. The tax is applied to the lesser of the recognized built-in gain ($25,000) or the taxable income limitation ($15,000). $15,000 * 21% = $3,150. The untaxed gain ($10,000) is carried forward to the next year.

Common mistakes

Ignoring the taxable income limitation; taxing the full gain realized ($30k) instead of the built-in portion ($25k).

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