User Account

All Pages

Liquadiation, Taxation

Assignment Help:
Realty Corporation owns a rental building (its only asset) with a gross fair market value of $1,000,000, subject to a nonrecourse mortgage of $400,000. Realty Corporation''s adjusted basis for this building is $300,000. Aaron owns all of Realty Corporation’s stock, with a total basis of $100,000. Realty Corporation has $200,000 of earnings and profits. Realty Corporation is on the accrual method of accounting and reports on the calendar year. Assume that the corporate tax payable by Realty Corporation on $700,000 gain is $250,000 and on $600,000 gain is $200,000.
For each of the following problems (1) through (7) below, determine the amounts and character of realized and recognized gain or loss to all parties, the time of recognition, and the transferee’s basis in any property received in kind. Each question should be reproduced in bold italic type, followed by your answer in normal type. They should simply be sufficient to answer the questions.
(1) Realty Corporation sells the building, subject to the mortgage, to Barbara in the current year for $600,000 in cash. Realty Corporation then liquidates, distributing to Aaron all of the cash remaining after paying its taxes, in cancellation of Aaron’s stock in the current year.
Alternatives:
(a) Barbara pays $300,000 cash and gives Barbara’s $300,000 note payable in equal annual installments over five years. Realty Corporation’s plan of liquidation provides that Realty Corporation will stay in existence for five years for the sole purpose of collecting the note and paying the net amount over to Aaron annually.b) Barbara pays $300,000 in cash and gives Barbara’s $300,000 (face and fair market value) note payable in equal annual installments plus interest over 5 years. In liquidation, Realty Corporation distributes the net cash and the note to Aaron in the year of sale.
(c) Change the facts in (1) and (1)(b) above to assume that Realty Corporation is an S corporation and § 1374 does not apply.
(2) Realty Corporation adopts a plan of complete liquidation and distributes the property to Aaron “in kind” pursuant to this plan. Aaron then sells the property to Barbara for $600,000 in cash, with Barbara taking subject to the $400,000 mortgage. Would it matter if Aaron’s shares had varying prices per share? What if the property were subject to contingent environmental liabilities?
Alternative: Realty Corporation is an S corporation and § 1374 does not apply.
(3) Aaron sells the stock in Realty Corporation to Barbara for $600,000 in cash. Barbara promptly liquidates Realty Corporation to get direct ownership of, and a $1,000,000 basis in, the building. Was Barbara wise to pay $600,000? Could Barbara obtain a better tax result by electing S corporation status for Realty Corporation before liquidating Realty Corporation?
Alternative: Realty Corporation always had been an S corporation.
(4) Suppose that in (1) above, the gross FMV of Realty Corporation’s property is actually $1,000,000, but to induce Realty Corporation to sell, Barbara also gives Realty Corporation a “contingent” right (with no ascertainable fair market value) to receive from Barbara an additional $500,000 in 5 years if Barbara earns profits from the building in excess of any profits it historically had earned.
(5) Suppose that in (2) above, the basis for Realty Corporation’s property is $1,500,000 instead of $300,000? Would your answer change if Aaron had organized Realty Corporation two years ago by contributing the building then worth $1,500,000 with a $1,500,000 basis in exchange for all the stock and Aaron’s stock basis is now $1,500,000 (assume no debt is involved)?
(6) Suppose that in (2) above, the value of Realty Corporation’s property is $350,000 and Realty Corporation liquidates with Aaron taking subject to the $400,000 mortgage. Aaron then sells to Barbara subject to the mortgage and for no additional consideration.
(7) Realty Corporation has one shareholder, Aaron, whose stock basis is $100,000. Realty Corporation operates a business in a building whose value is $1,000,000 with an adjusted basis of $300,000. Realty Corporation has $1,000,000 in the bank. In the current year, Realty Corporation sells its operating business assets for $1,000,000 cash, which increases Realty Corporation’s total earnings and profits to $1,500,000. Also in the current year, in exchange for other assets Realty Corporation receives an installment note reportable under § 453, enters into a lease for the building with the buyers of its business, and retains part of its inventory for gradual sale in the future. Aaron, who isage 70, comes to you after all these steps have been taken and inquires whether Realty Corporation should be liquidated or should elect S corporation status to avoid paying double tax on the installment gain, the rent, the future inventory sales, and a possible sale of the building in a few years. What do you advise?

Related Discussions:- Liquadiation

Describe what is the incidence of tax, Tax incidence can be separated into-...

Tax incidence can be separated into- 1. Formal incidence: the party liable to the tax 2. Informal incidence: party, who really pays the tax The tax incidence is decided by t

., Alan is an employee at ABC Pty Ltd (ABC). He has negotiated the followin...

Alan is an employee at ABC Pty Ltd (ABC). He has negotiated the following remuneration package with ABC: • salary of $300,000; • Payment of Alan''s mobile phone bill ($220 per mont

Determine method of money transfer, Ted Testator died January 1st of this y...

Ted Testator died January 1st of this year.  Ted was married to Teri at the time of his death, but has two children, Timothy and Tabitha, from a prior marriage. You have been hired

#CST, there is customer invoice booked with cst 2% (tru AFP) and now the cu...

there is customer invoice booked with cst 2% (tru AFP) and now the customer says he wont provide c from.. so now we hv to charge extra 3% cst.. how to book this

Sales tax, I got confused with the numbers on these parts: 1. "The $3,600 o...

I got confused with the numbers on these parts: 1. "The $3,600 of property taxes for the house in Orlando were prorated with $1,950 being apportioned to the seller and $1,650 being

Taxable income, The following 2012 projected income statement is provided b...

The following 2012 projected income statement is provided by your new client, John Green, single, and sole proprietor of Green Industries. Green Industries started business in Marc

Compute section 179 deduction and taxable income, Loni Company paid $ 527,0...

Loni Company paid $ 527,000 for tangible personalty in 2011 and elected to expense $ 500,000 of the cost (the limited dollar amount for 2011). Loni's taxable income before a Sectio

Toledo ABC Doctors, need tax help requiring tax forms

need tax help requiring tax forms

Income tax, income tax and its many types

income tax and its many types

Advanced tax, The Madison Restaurant was formed a S corporation at the end ...

The Madison Restaurant was formed a S corporation at the end of last year. Bob Buron, owns 60% of the stock, manages the restaurant. Ray Huges owns the remaining 40%

Write Your Message!

Captcha
Order Assignment

Featured Services

Order Now

Popular Subjects

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!

Submit Assignment

Academics

Major Subjects

Majors

Get In Touch

whatsapp: +91-977-207-8620

Phone: +91-977-207-8620

Email: [email protected]

TERMS & POLICIES

HELP & SUPPORT

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd