As per Section 351 any loss will not be realized but if any boot is received along with the qualified stock then the stock and boot will be allocated on pro-rata basis on the basis of the different types of property transferred. Loss on one asset will not be allowed to set off from the gain of another.
Basis | FMV |
Share and boot (pro-rata) |
Gain/(loss) | |
Asset 1 | 40,000 | 30,000 | 39,024 | 9,024 |
Asset 2 | 15,000 | 40,000 | 14,634 | (25,366) |
Asset 3 | 27,000 | 10,000 | 26,341 | 16,341 |
Total stock and boot: 80,000 (20,000+60,000)
Total of basis: 82,000
Divide on pro rata basis:
Asset 1: 80,000*40,000/82,000= 39,024
Asset 2: 80,000*15,000/82000= 14,634
Asset 3: 80,000*27,000/82,000= 26,341
w 5. Section 351 Multiple Assets Transfer - Exercise Xercise Zhang transfers three assets to newly...
PROBLEM 1: Jerry transfers two assets to a corporation as part of a Sec. 351 exchange. The first asset has an adjusted basis of $70,000 and an FMV of $50,000. The second asset has an adjusted basis of $70,000 and an FMV of $150,000. The FMV of the stock received is $180,000, and he also receives $20,000 cash. The realized and recognized gain on the second asset is A) $80,000 realized; $20,000 recognized. B) $80,000 realized; $15,000 recognized. C) $20,000...
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