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

Wacc, The cost of capital for a firm can differ from the cost of capital fo...

The cost of capital for a firm can differ from the cost of capital for each of its businesses. When a firm has multiple businesses, it is important to use the cost of capital appro

What are "in-market" mergers, What are "in-market" mergers? A: An in-ma...

What are "in-market" mergers? A: An in-market merger is one that takes place between two banks operating in the same geographic area, typically a city or metropolitan area. The

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?

Top flop division - forecasting methods, Top-flop division is based on the ...

Top-flop division is based on the idea that the demand percentages of the 'top' and the 'flop' SKUs in a group of SKUs are fairly stable over time. For example, the 33% best-sellin

Evaluate the capital structure, Question: (a) According to Modigliani a...

Question: (a) According to Modigliani and Miller's Theory of Capital Structure (1963), companies should make maximum use of gearing. Briefly, describe factors which might pr

Equal division - forecasting methods, Equal division divides M equally over...

Equal division divides M equally over the SKUs in N. Thus, There are two main reasons for including this simplistic approach. First, the approach is used by the case compan

Calculate the cost of equity capital, Question: (a) As the cost of capi...

Question: (a) As the cost of capital is an essential element of investment appraisal, its calculation must be undertaken with care. Failure to do so could lead to adverse cons

Compute the expected return, You have ten million dollars to allocate acros...

You have ten million dollars to allocate across two projects, code named 'Wombat' and 'Marmot.' Both projects are somewhat scalable, in that you could potentially invest as much (u

INVESTMENT DECISION, You are a ceo of a sotware firm that has limited acces...

You are a ceo of a sotware firm that has limited access to debt equity markets. The average return on last year projects is 28 % . and cost of capital is 12%. would npv pr Irr be

Distinguish between exchange traded instruments, Question: (a) What are...

Question: (a) What are the differences and similarities between futures and forwards? (a) Distinguish between exchange traded instruments and over the counter instruments

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