Corporate Formations Problem
Mary and Todd form the MT Corporation, with a transfer of the following properties:
Mary $1,200,000 cash
Todd $800,000 FMV property
$300,000 tax basis
Mary will receive 60% and Todd 40% of the corporate stock.
Complete the following
Mary Todd
Realized gain ________ ________
Recognized gain ________ _________
Basis of Stock _________ _________
MT basis in contributed asset __________ _________
VARIATION 1: return to original facts (no Karla). Todd’s property is valued at $1,100,000 but is contributed subject to a $300,000 liability.
Complete the following
Mary Todd
Realized gain ________ ________
Recognized gain ________ _________
Basis of stock _________ _________
MT basis in contributed asset __________ _________
VARIATION 2: Same as Variation 1 except Todd’s property is valued at $1,200,000 and is contributed subject to a liability of $400,000.
As per section 351, when cash and/or any property is transferred to C Corp. and these contributed capital by one or more of the shareholder constitues 80% or more control in the C corp. then such contributions made by shareholder will not be taxable.
As per sec 351,
Shareholder basis for stock= carryover basis of the shareholder - mortgage debt (if any)
Corporation's basis for property = Carryover basis of the shareholder
Variation 1: -
Variation 2: -
But exception to section 351 will be considered here as mortgage debt exceeds shareholder's adjusted basis in the property.
Also, corporate's basis for property = Carryover basis + gain recognized
Here, gain will be recognized on excess liability so that shareholder's adjusted basis is $0,
Hence, Tod's basis for stock = $300,000 - $400,000 +$100,000
MT corp's basis in the property = $300,000 + $100,000 = $400,000
For any clarification, please comment. Kindly Up Vote!
Corporate Formations Problem Mary and Todd form the MT Corporation, with a transfer of the following...
Mary and Todd from the MT Corporation, with a transfer of the
following properties:
Mary
$1,200,000 cash
Todd
$800,000 FMV property
$300,000 tax basis
Mary will receive 60% and Todd 40% of the corporate stock.
Complete the following
Mary
Todd
Realized
gain
________
________
Recognized
gain
________
_________
Basis of
stock
_________
_________
MT basis in contributed
asset
__________
_________
VARIATION 2: Same as Variation 1 except Todd’s property...
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Please show your work
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