6. A, an individual, owns 100% of X Co.
a. X distributes a parcel of land with a basis of $40 and a fair
market value of $100 to A. What gain or loss does X have from this
transaction?
b. Suppose instead that X distributes a piece of equipment with a
cost of $60 and accumulated depreciation of $20. Assume that A will
use the asset in A's business. Will these facts change your
answer?
c. Same as (a) except that the land has a FMV of $30. How will this
change your answer?
d. What impact does the distribution have on the E&P of
X?
e. What is the amount of distribution to A? What basis will A have
in the land?
f. Same as (e) except that the land is subject to a mortgage of
$20. Discuss how this will change your analysis.
a. Gain of $40.
b. Gain of $60.
c. Gain of $12.
d. There will be no impact the distribution have on the E&P of X.
e. $100
f. $80
6. A, an individual, owns 100% of X Co. a. X distributes a parcel of land...
Ben Corp distributes a parcel of land to its sole shareholder sera. The fair value of the land is $30,000. The basis of the land to the corporation is $25,000. The land has a mortgage in the amount of $28,000 that is assumed by sera. What are the consequences to sera and to Ben Corporation. Assume that the earning and profits are $300,000.
3. In a liquidating distribution, Business Corporation distributes land to its shareholder Ferrell (an individual). Business Corporation acquired the land in a §351 transfer 6 year ago from Ferrell. At the time of the transfer into the Corporation, the land had basis of $700,000 and FMV of $1,000,000. At the time of distribution to Ferrell, the FMV of the land is $500,000. Ferrell owns 40% of the corporation and his stock basis is $150,000. Ferrell’s sister owns the remaining 60%...
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Walker Corporation distributes to its shareholder Brayden (an individual s/h) a piece of land with FMV $1,000,000. Walker purchased the land ten years ago for $600,000. Walker’s current E&P is $200,000 and its accumulated E&P is $50,000. Brayden’s stock basis is $475,000. Brayden owns 85 shares (85%) of Walker Corporation. The remaining 15 shares (25%) are owned by an unrelated party. (6.5 Points) What are the tax consequences to Walker Corp and Brayden if this is a nonliquidating distribution? What...
Corporation W onws 100% of the common stock of Corporation Z with a basis of $300. Z owns a rental building (its only assets) with a gross fair market value of $3,000, subject to a non-recourse mortgage of $1,200. Z's adjusted basis for this building is $900. Z has $600 of E&P. Z is on the accrual method of accounting and reports on the calendar year. Z and W do not report on a consolidated basis. Z distributes the building...
On May 10 of the current year, Newport Corporation distributes to its shareholder Helen $22,000 in cash and land (a capital asset) having a $30,000 FMV. The land has a $26,000 adjusted basis (for both taxable income and E&P purposes) and is subject to a $55,000 mortgage, which Helen assumes. Newport has an E&P balance exceeding the amount distributed and is subject to a 21% corporate tax rate. Read the requirements Requirement a. What are the amount and character of...
Please show your work.
2. Green, Inc., a C corporation, distributes a tract of land held as an investment (FMV S500,000, basis $220,000) and its mortgage of $550,000 to Susan in return for 50 of her shares at the end of the year. Green, Inc. has a current E&P of $190,000 for the year, and started the year an accumulated E & P of $60,000. Green's marginal tax rate is 21%. Susan has an individual marginal tax rate of 33%...
Iris Corporation owns 30% of Fresia Corporation's stock. On November 15, Fresia Corporation, with current E & P of $320,000, distributes land (fair market value of $100,000; basis of $160,000) to Iris. The land is subject to a liability of $80,000, which Iris assumes. Dividends Received Deduction Percentage of Ownership by Corporate Shareholder Deduction Percentage Less than 20% 50% 20% or more (but less than 80%) 65% 80% or more* 100% a. How is Iris Corporation taxed on the distribution?...
Iris Corporation owns 30% of Fresia Corporation's stock. On November 15, Fresia Corporation, with current E & P of $320,000, distributes land (fair market value of $100,000; basis of $160,000) to Iris. The land is subject to a liability of $80,000, which Iris assumes. Dividends Received Deduction Table Percentage of Ownership by Corporate Shareholder Deduction Percentage Less than 20% 50% 20% or more (but less than 80%) 65% 80% or more 100% a. How is Iris Corporation taxed on the...
Without liquidating, Blue Corporation distributes equipment with a $90,000 adjusted basis and a $120,000 FMV to Sue. The equipment is subject to a $30,000 mortgage assumed by Sue. Blue has $320,000 of E&P (excluding the distribution) Requirements a. How much gain (if any) does Blue recognize on the distribution of the equipment? b. What distribution amount is taxable as a dividend to Sue? c. What is Sue's basis in the equipment? Requirement a. How much gain (if any) does Blue...