for a taxpayer transferring property to a corporation in a section 351 transaction the stock received in the transfaction is given a carryover basis. true or false
In a 351 transaction any corporate debt or securities received are treated as boot because they donot qualify as stock. true or false
Questions :-for a taxpayer transferring property to a corporation in a section 351 transaction the stock received in the transaction is given a carryover basis
Answer : FALSE
Questions :-In a 351 transaction any corporate debt or securities received are treated as boot because they donot qualify as stock
Answer : TRUE
Any corporate debt or securities (long term debt like bonds) received are treated as boot because they do not qualify as stock - causes recognition of gain
for a taxpayer transferring property to a corporation in a section 351 transaction the stock received...
Question 1) What is a carryover basis as it relates to property received by a corporation in a §351 transaction? What is the purpose of attaching a carryover basis to property received in a §351 transaction? Under what circumstances does property received by a corporation in a §351 transaction not receive a carryover basis? What is the reason for this rule? What is a substituted basis as it relates to stock received in exchange for property in a §351 transaction?...
Discussion Question 4-11 (LO. 3) With respect to the calculation of the basis of stock received by a shareholder in a $ 351 transfer, label each of the following as being either "True" or "False" a. If a shareholder transfers a liability to the corporation along with property, the basis in the stock received is reduced by the amount of the liability transferred to the corporation. b. Section 362(e)(2) generally requires the corporation to step down the carryover basis for...
(13) Identify which of the following statements is true. A) If stock and boot property are both received in a Sec. 351 exchange, the transferor must allocate the total basis in the contributed property between the stock and boot property based on the relative FMVs of the stock and the boot property. B) The adjusted basis of stock received in a Sec. 351 transaction is computed by deducting the deferred loss from the FMV of the stock received. C) The...
When a taxpayer transfers property subject to a mortgage to a controlled corporation in an exchange qualifying under § 351, the transferor shareholder’s basis in stock received in the transferee corporation is increased by the amount of the mortgage on the property. True or False? Please explain.
ORGANIZATION OF A CORPORATION: SECTION 351 and RELATED PROBLEMS 3B Boot; Basis; Debt; “Midstream” Issues (1)(a) Section 351(a) applies. Upon exchange with X, (1) A’s amount realized is $100; (2) A’s gain realized is $60; (3) nothing is recognized, because of § 351(a); (4) A’s basis in stock received is $40 under § 358(a)(1); (5) A’s holding period in the stock tacks under § 1223(1); (6) X’s basis in property is $40 under § 362(a)(1); (7) X’s holding period for...
Because services are not considered property under 5 351, a taxpayer must report as income the fair market value of stock received for such services, O True False 216833
14-19 please 14. For Section 351 transfers, immediately after the exchange a. requires simultaneous transfer, if two or more transferors b. allows transfers to occur up to two years apart c. allows transfers to occur up to three years apart d. means that transfers should occur as close together as possible e, none of the above 13. Section 351 transfers for property and services are acceptable as long as the property value is at least a. 5% of the value...
Services are not considered property for the purposes of an IRC Section 351 transfer a contributing shareholder receiving shares in exchange for the services rendered basis in the shares received. a. True b. False
Doug, Elbert, and Fran form DEF Corporation by transferring the following: From Transferor Property Transferred Stock Received 10-Year Notes Doug $75,000 $75,000 $0 Elbert $25,000 $25,000 $0 Fran $25,000 $0 $25,00 Would Does the above transfer qualify Doug and Elbert for nonrecognition of gain or loss under Code Sec. 351? A. No, the note disqualifies the transfer. B. No, control was not obtained in the transfer. C. Yes, the note is not considered stock and control is obtained D. Yes,...
A shareholder's holding period for stock received under $ 351 can include the holding period of the property transferred to the corporation. True False LITTLI ..