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

Risk-return relationship, Problem 1 What is a bill of exchange? Explain...

Problem 1 What is a bill of exchange? Explain carefully the requisites for a bill of exchange to be valid.  Problem 2 You have a close friend, Peter, who is a renowned

Calculate the annual economic value added, Westbrook Inc. is financed with ...

Westbrook Inc. is financed with debt that costs it 5% (pre-tax)or $12.5m annually and expects to generate an EBITof $50m per year perpetually. The company is at its target debt/eq

Prepare a basic master budget, The first part requires you to prepare a bas...

The first part requires you to prepare a basic master budget. The general description is provided in Part A, in this document. However the data for the assignment is to be obtained

Determine the securities debt or equity of x , X has 10 shareholders, each ...

X has 10 shareholders, each of whom owns 100 of its 1,000 outstanding shares of common stock (worth $100 per share).  No other stock is outstanding.  Determine whether the securiti

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

Accumulated dividend, It is a dividend on a share of cumulative preferred s...

It is a dividend on a share of cumulative preferred stock that has not still being paid to the shareholder. Accumulated dividends are the product of dividends that are carried forw

Impact of cost structure, You are required to provide a report of approx 50...

You are required to provide a report of approx 500 words or less (excluding attachments and references), accompanied by relevant calculations, in MS Word, MS Excel and/or PDF forma

Online assignment, what will be the impact on operating leverage if it is p...

what will be the impact on operating leverage if it is proceeds for additional borrowings

New value of the equity, GeKay is now considering issuing $3 million in deb...

GeKay is now considering issuing $3 million in debt, and paying $150,000 yearly in interest at 5%, that it would keep rolling over "forever" (in perpetuity). The proceeds would

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