Instructions For 2014 Schedule 4w: Wisconsin Subtractions From Federal Income

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Instructions for 2014 Schedule 4W:
Wisconsin Subtractions from Federal Income
Purpose of Schedule 4W
substantially returned to the taxpayer, either di-
rectly or indirectly.
Corporations complete Schedule 4W to report sub-
If the transaction was entered on the advice of a
traction modifications that are needed to account for
tax advisor, the advisor’s fee was determined by
differences between taxable income under Wisconsin
reference to the tax savings.
law and under federal law. The corporation files
Schedule 4W with its Wisconsin Form 4.
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 4Y. See the Schedule 4Y instructions for an ex-
Treas. Reg. 1.482-1(b).
planation 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 made an addition modification for related entity
income and expenses.
expenses on Schedule 4V, line 3, this is where you
report the amount that qualifies for a deduction. Enter
An expense for the transaction was accrued un-
the amount of the expenses from Schedule 4V, line
der FIN 48.
3, that are deductible using the criteria described in
Conditions for Deducting Related Entity Expenses,
The statutes (sec. 71.80(23)(a)1. and 2., Wis. Stats.)
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 ben-
ject to some important exceptions. Those conditions
eficiaries of pass-through entities, also include the
are:
amount of allowable related entity expense reported
on line 21b of Schedule 3K-1 and on line 14b of
If the expense was paid to a related entity that is
Schedule 2K-1, as applicable.
merely acting as a conduit between the taxpayer
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
come or receipts of the transaction were included
back on Schedule 4V, line 3, qualifies for a deduction
in its tax base.
if all of the following conditions are met:
More Information on Related Entity Expenses. For
The primary motivation for the transaction was
more information on the deductibility of related entity
one or more business purposes other than the
expenses, see the Schedule RT instructions. Even if
avoidance or reduction of state income or fran-
you weren’t required to file Schedule RT for the ex-
chise taxes;
penses you added back on Schedule 4V, the instruc-
The transaction changed the economic position
tions to Schedule RT provide helpful information re-
of the taxpayer in a meaningful way apart from
garding deductibility of related entity expenses.
tax effects; and
■ Line 3. Income from Related Entities Whose
The expenses were paid, accrued, or incurred
Expenses Were Disallowed – If the corporation has
using terms that reflect an arm’s length relation-
income from a related entity which paid, accrued, or
ship.
incurred expenses to the corporation, and that related
entity could not deduct those expenses according to
Factors that may indicate that the expense does not
the instructions for line 2, the corporation may sub-
qualify for a deduction include the following:
tract the corresponding income from its taxable in-
come.
There was no actual transfer of funds from the
taxpayer to the related entity, or the funds were
IC-024

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