Instructions For 2009 Schedule W: Wisconsin Subtractions From Federal Income

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Instructions for 2009 Schedule W:
Wisconsin Subtractions from Federal Income
Purpose of Schedule W
back on Schedule V, line 3, qualifies for a deduction if
all of the following conditions are met:
Corporations and combined groups complete Sched-
The primary motivation for the transaction was
ule W to report subtraction modifications that are
one or more business purposes other than the
needed to account for differences between taxable
avoidance or reduction of state income or fran-
income under Wisconsin law and under federal law.
chise taxes;
The corporation or combined group files Schedule W
with its Wisconsin Form 4 or Form 5.
The transaction changed the economic position
of the taxpayer in a meaningful way apart from
tax effects; and
Special Instructions for Combined Groups
The expenses were paid, accrued, or incurred
For combined groups, you do not need to file more
using terms that reflect an arm’s length relation-
than one Schedule W. Instead, you may aggregate
ship.
all combined group members’ subtractions from fed-
eral income on one Schedule W and submit a sup-
Factors that may indicate that the expense does not
plemental schedule showing the amount of each sub-
qualify for a deduction include the following:
traction modification attributable to each member.
There was no actual transfer of funds from the
taxpayer to the related entity, or the funds were
CAUTION: When completing Schedule W for a
substantially returned to the taxpayer, either di-
combined group, make sure that the amounts you
rectly or indirectly.
are subtracting were included in the amount on
Form 4, line 1 to begin with. Do not make
If the transaction was entered on the advice of a
subtraction modifications for corporations that are in
tax advisor, the advisor’s fee was determined by
the federal consolidated return but that aren’t
reference to the tax savings.
members of the combined group.
The related entity does not regularly engage in
similar transactions with unrelated parties on
terms substantially similar to those of the subject
Line-by-Line Instructions
transaction.
■ Line 1. Wisconsin Subtraction Modification for
The transaction was not entered into at terms
Dividends – Enter the total from line 4 of Sched-
comparable to arm’s length as determined by
ule Y. See the Schedule Y instructions for an expla-
Treas. Reg. 1.482-1(b).
nation of dividends that are eligible for the subtrac-
tion.
There was no realistic expectation of profit from
the transaction apart from the tax benefits.
■ Line 2. Related Entity Expenses – If the corpora-
The transaction resulted in improper matching of
tion or combined group made an addition modifica-
income and expenses.
tion for related entity expenses on Schedule V, line 3,
this is where you report the amount that qualifies for
An expense for the transaction was accrued un-
a deduction. Enter the amount of the expenses from
der FIN 48.
Schedule V, line 3, that are deductible using the crite-
ria described in Conditions for Deducting Related En-
The statutes (sec. 71.80(23)(a)1. and 2., Wis. Stats.)
tity Expenses, below.
provide some additional conditions under which a re-
lated entity expense may qualify for a deduction, sub-
For corporations that are partners, members, or
ject to some important exceptions. Those conditions
beneficiaries of pass-through entities, also include
are:
the amount of allowable related entity expense re-
If the expense was paid to a related entity that is
ported on line 21b of Schedule 3K-1 and on line 14b
merely acting as a conduit between the taxpayer
of Schedule 2K-1, as applicable.
and an unrelated entity, or
Conditions
for
Deducting
Related
Entity
If the related entity was subject to a tax meas-
Expenses. Section 71.80(23)(a)3., Wis. Stats.,
ured by net income or receipts and the net in-
provides that a related entity expense that was added
IC-124 (Rev. 2/1/10)

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