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Topic
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In the current year, Brown, a C corporation, has gross income (before dividends) of $900,000 and deductions of $1,100,000 (excluding the dividends-received deduction). Brown received dividends of $100,000 from a Fortune 500 corporation during the current year. What is Brown’s net operating loss?
Answer and explanation: $170,000
This answer is correct. The requirement is to determine the amount of Brown Corporation’s net operating loss. For the year, Brown had gross income (other than dividends) of $900,000, received dividends of $100,000, and had deductions of $1,100,000, resulting in a net operating loss of $100,000 before subtracting a dividends-received deduction (DRD). It should be assumed that Brown owned less than 20% of the Fortune 500 corporation that paid the dividend, making the dividend eligible for a 70% DRD. The resulting DRD of $100,000 × 70% = $70,000 increases the net operating loss to $170,000.
I do not think one should simply assume “that Brown owned less than 20% of the Fortune 500 corporation”.
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