Determining the contributing property, Corporate Finance

Assignment Help:

1. A contributes property to X, a newly formed corporation, in exchange for 75 shares.  As part of the same transaction, B contributes services to X in exchange for the remaining 25 shares.  Does § 351 apply to the contributions of A and B? Why or why not?

2. A contributes to X, a newly formed corporation, property worth $80 with a basis of $60 in exchange for 20 shares.  Assume the stock is worth $1 per share.  As part of the same transaction, B contributes to X property worth $20 with a basis of $10 in exchange for 80 shares.  How much income must A and B recognize and why (assume that if § 351 applies, A's basis in the stock A receives is the same as A's basis in the property A contributes)?

3.  In each of the following scenarios, determine in regards to the exchange with X:

a)      A's amount realized

b)      A's gain or loss realized

c)      A's gain or loss recognized and the character thereof

d)     A's basis in the X stock received

e)      A's holding period for the X stock received (tacked or not?)

f)       X's basis in the property received

g)      X's holding period for the property received (tacked or not?)

h)      The amount and character of X's gain if X immediately sells the property for $100

      And the following in regards to the subsequent sale from A to B:

i)        A's gain or loss realized

j)        A's gain or loss recognized and the character thereof

k)      A's basis in the remaining shares

l)        B's basis in the purchased shares from A

Assumptions: Except as otherwise stated, A starts out with non-depreciable real property (a capital asset) worth $100 (adjusted basis $40) and ends up with cash of $50 plus a 50% interest (worth $50) in X, a newly organized corporation that owns the property.

(a)    A transfers the property to X in exchange for all of X's stock.  Shortly thereafter, A sells half of his X stock to B for $50.  The stock sale is a "separate" event from the prior incorporation transaction.

(b)   Same as (a), except the stock sale is an integral part of the incorporation plan.


Related Discussions:- Determining the contributing property

International finance - determine sources of foreign capital, International...

International Finance - Determine the sources of Foreign Capital? 1. Determine the sources of Foreign Capital? 2. What are the reasons that evaluate foreign Project? 3. D

Bond valuation, An investor buys a French government, 10-year bond, paying ...

An investor buys a French government, 10-year bond, paying annual coupon of 4.5%. Face value = 1000. The investor is unsure of his investment horizon and considers 5 horizons: 5, 6

IRR & WACC, I have been given 3 different types of projects. They state th...

I have been given 3 different types of projects. They state the IRR and how much the project will add. The question goes on to give a WACC with break points. The question wants

Accuracy of initial forecast, The bulk of products is produced in South Eas...

The bulk of products is produced in South East Asia, and hence the lead time to Western retailers is long. The typical lead time from fabric manufacturers is 3 months (Gutgeld and

Financial modelling, Financial Modelling Read carefully the case notes ...

Financial Modelling Read carefully the case notes overleaf. Factor models on explaining firm's returns in a credit risk context. Is the usual one-factor model good enough?

Finance, Question 5 A company has a total investment of Rs 500,000 in asset...

Question 5 A company has a total investment of Rs 500,000 in assets, and 50,000 outstanding ordinary shares at Rs 10 per share (par value). It earns a rate of 15 per cent on its in

How could phoenix activity be addressed, Q. How could phoenix activity be a...

Q. How could phoenix activity be addressed? A range of actions have been suggested to mitigate phoenix activity. These suggested actions were selected on the basis of: - pr

Sensitivity analysis, NPV calculation if we have Initial investment 60000,l...

NPV calculation if we have Initial investment 60000,life is 3 year, net working capital is 15000, sale is 75000 per year, variable cost is 1000 per year, fixed cost is 5000 per yea

Allocative & pricing efficiency, differentiate between allocative efficienc...

differentiate between allocative efficiency and pricing efficiency

Write Your Message!

Captcha
Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd