This lucky event increased Firm LK’s net worth by $72,000 and, therefore, resulted in $72,000 realized income to the firm. 4. If the two corporations have different marginal tax rates, an intercompany transaction could result in a shift of income from the high tax entity to the low tax entity or a shift of a deduction from the low tax entity to the high tax entity. A method of accounting that accomplishes such a shift and does not reflect an arm’s length transaction price between the related corporations is highly vulnerable to IRS challenge…
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