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

Calculate the stock rate of distribution, A owns all of the stock of X.  Th...

A owns all of the stock of X.  The stock's basis is $100.  X has a total of current and accumulated earnings and profits of $50.  X distributes $200 cash to A "with respect to his

Modigliani–miller theorem, The FrontczakCompany is expecting to generate (a...

The FrontczakCompany is expecting to generate (after tax)a Net Income of $250 millionannuallyandindefinitely (in perpetuity), and this amount is paid out annually as dividends. T

Touring enterprises, what is the major value of the weighted cost of capita...

what is the major value of the weighted cost of capital calculation for the firm?

Real vs nominal discount rates, impact of real and nominal discount rates i...

impact of real and nominal discount rates in capital budgeting

Cost of capital, How does cost of capital vary with debt-to-value ratio?

How does cost of capital vary with debt-to-value ratio?

Forecasting demand for single-period, In the apparel industry, three promin...

In the apparel industry, three prominent developments contribute to the complexity of forecasting: shortening product life-cycles, increasing product variety, and globalization of

Efficiency, differentiate between allocative efficiency and pricing efficie...

differentiate between allocative efficiency and pricing efficiency.

Why the discount rate equals opportunity cost of capital, Question: (a)...

Question: (a) Describe why the discount rate equals opportunity cost of capital? (b) "Nominal rate less inflation rate is equal to real rate of return" - Is it true? Why or

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