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

Net present value, Based on its Net Present Value (NPV), should the followi...

Based on its Net Present Value (NPV), should the following project be accepted?  Please assume a discount rate of 10%.

Hw question on IRR, Your firm is contemplating the purchase of a new $791,0...

Your firm is contemplating the purchase of a new $791,000 computer-based order entry system. The system will be depreciated straight-line to zero over its seven-year life. It will

Do mergers result in layoffs?, Do mergers result in layoffs? A: Overall...

Do mergers result in layoffs? A: Overall employment in the banking industry actually has increased slightly over the last ten years. Some mergers do result in layoffs. However,

Epact 179d accelerated depreciation, Explain in detail, using the time valu...

Explain in detail, using the time value of money,if its better to receive a 685k tax deduction in 1 year vs 17,564.10 each year for 39 years.(inflation, opportunity cost, etc...) T

Explain the traditional view of credit risk, The traditional view of credit...

The traditional view of credit risk relates to borrowers, firms, individuals, or financial institutions. Nevertheless, more and more specialized finance transactions deal with str

Liquidity, What are the objectives of determinants of liquidity?

What are the objectives of determinants of liquidity?

Rate of growth in a countrys national income, Problem: i) Consider the...

Problem: i) Consider the following apparently contradictory statements: a) ‘ an increase in the rate of growth in a country's national income relative to that in the rest

What you understand by good corporate governance framework, Question: a...

Question: a) Explain what you understand by good corporate governance framework and its application to the local context. b) ‘The Borrower Protection Act 2007 was en

Business finance task, Your company is considering using the payback period...

Your company is considering using the payback period for capital-budgeting. Discuss the advantages and disadvantages of this technique. Your company is considering the constructio

Describe statistical control- product and services, This subject has a majo...

This subject has a major individual assignment consisting of a number of tasks (parts). The assignment has been designed with the aim of providing you a practical application case

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