Mariano owns all of Alpha Corporation, which owns 100% of Beta Corporation's single class of stock....
Mariano owns all of Alpha Corporation, which owns 100% of Beta Corporation's single class of stock. On January 1, Alpha and Beta Corporations report a consolidated NOL carryover from prior years. What is the maximum percentage of Alpha Corporation's single class of stock that Mariano can sell to a single shareholder without triggering the Sec. 382 loss limitation?
Homework Answers
Answer 5%
A ownership is generally as a greater than 50% change in the ownership of stock among certain 5% share holders over a 3 years period u/s 382(g)
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Mariano owns all of Alpha Corporation, which owns 100% of Beta
Corporation's single class of stock....
Question Completion Status: QUESTION1 Alpha Corporation owns 100 percent of Beta Company, and Beta owns 80...
Question Completion Status: QUESTION1 Alpha Corporation owns 100 percent of Beta Company, and Beta owns 80 percent of Gamma, Inc, all of which are domestic corporations. There were no excess allocation values at the date of acquisition of the subsidiaries. Information for the three companies for the year ending December 31, 2018 follows: Alpha 300, Beta Gamma 100, Separate company net income Gross profit from intra-entity transfers of inventory (included in operating income above). The goods have not yet been...
12) Isabella owns all 100 shares of Finch Corporation's stock, valued at $100,000. Abigail owns property...
12) Isabella owns all 100 shares of Finch Corporation's stock, valued at $100,000. Abigail owns property that has a $15,000 adjusted basis and a $100,000 FMV. Abigail contributes the property to Finch Corporation in exchange for 100 shares of newly issued Finch stock. Does Sec. 351 apply to Abigail's exchange? What is the amount of her realized gain or loss? How much is recognized?
42. Halperin Corporation owns stock of Leon Corporation. For Halperin and Leon to qualify for the...
42. Halperin Corporation owns stock of Leon Corporation. For Halperin and Leon to qualify for the filing of consolidated returns, at least what percentage of Halperin's total voting power and total value of stock must be directly owned by Leon? A) Total voting Total Value of power stock 51% 51% B) Total voting Total Value of power stock 51% 80% C) Total voting Total Value of power stock 80% 80% Total voting power 80% Total Value of stock 51% 43....
42. Halperin Corporation owns stock of Leon Corporation. For Halperin and Leon to qualify for the filing of consolid...
42. Halperin Corporation owns stock of Leon Corporation. For Halperin and Leon to qualify for the filing of consolidated returms, at least what percentage of Halperin's total voting power and total value of stock must be directly owned by Leon? A) Total voting power 51% Total Value of stock S1% B) Total voting Total Value of power 51% stock 80% C) Total voting Total Value of stock power 80% 80% D) Total voting Total Value of stock 51% power S0%...
EXHIBIT 16-6 Stock Ownership and Dividends Received Deduction Percentage | Receiving Corporation's Stock Ownership in Distributing...
EXHIBIT 16-6 Stock Ownership and Dividends Received Deduction Percentage | Receiving Corporation's Stock Ownership in Distributing Corporation's Stock Less than 20 percent At least 20 percent but less than 80 percent 80 percent or more Dividends Received Deduction Percentage 50% 65 100 * To qualify for the 100 percent dividends received the receiving and distributing corporations must be in the same affiliated group as described in $1504. The 80 percent ownership requirement is the minimum ownership level required for inclusion...
Iris Corporation owns 30% of Fresia Corporation's stock. On November 15, Fresia Corporation, with current E...
Iris Corporation owns 30% of Fresia Corporation's stock. On November 15, Fresia Corporation, with current E & P of $320,000, distributes land (fair market value of $100,000; basis of $160,000) to Iris. The land is subject to a liability of $80,000, which Iris assumes. Dividends Received Deduction Percentage of Ownership by Corporate Shareholder Deduction Percentage Less than 20% 50% 20% or more (but less than 80%) 65% 80% or more* 100% a. How is Iris Corporation taxed on the distribution?...
Iris Corporation owns 30% of Fresia Corporation's stock. On November 15, Fresia Corporation, with current E...
Iris Corporation owns 30% of Fresia Corporation's stock. On November 15, Fresia Corporation, with current E & P of $320,000, distributes land (fair market value of $100,000; basis of $160,000) to Iris. The land is subject to a liability of $80,000, which Iris assumes. Dividends Received Deduction Table Percentage of Ownership by Corporate Shareholder Deduction Percentage Less than 20% 50% 20% or more (but less than 80%) 65% 80% or more 100% a. How is Iris Corporation taxed on the...
Elm Corporation has 100 shares of stock outstanding of which Oak Corporation owns 75 shares with...
Elm Corporation has 100 shares of stock outstanding of which Oak Corporation owns 75 shares with a basis of $10,000, and Sherman Forest owns 25 shares with a basis of $30,000. Elm Corporation has a $50,000 net operating loss carryover and the following assets (all held long-term): Basis Fair Market Value Cash $20,000 $20,000 Installment Note $10,000 $40,000 Land $1,000 $10,000 Equipment (all Sec. 1245 recapture) $5,000 $10,000 $36,000 $80,000 What are the tax consequences if Elm Corporation adopts...
VERSION A: 2019 ACCT 4210A: IN CLASS EXERCISE: LIQUIDATIONS (5 POINTS) 1. (1 POINT) Which I...
VERSION A: 2019 ACCT 4210A: IN CLASS EXERCISE: LIQUIDATIONS (5 POINTS) 1. (1 POINT) Which I of the following would not be considered a sufficient reason for Chrysler Corp to liquidate? a Chrysler Corp liquidated when the Securities and Exchange Commission (SEC) began to investigate it for securities fraud b. By Chrysler Corp liquidating and re-forming as a limited liability company, Chrysler will eliminate double taxation c. Chrysler Corp's board of directors decided to liquidate Chrysler because Chrysler was not...
VERSION A: 2019 ACCT 4210A: IN CLASS EXERCISE: LIQUIDATIONS (5 POINTS) 1. (1 POINT) Which I...
VERSION A: 2019 ACCT 4210A: IN CLASS EXERCISE: LIQUIDATIONS (5 POINTS) 1. (1 POINT) Which I of the following would not be considered a sufficient reason for Chrysler Corp to liquidate? a Chrysler Corp liquidated when the Securities and Exchange Commission (SEC) began to investigate it for securities fraud b. By Chrysler Corp liquidating and re-forming as a limited liability company, Chrysler will eliminate double taxation c. Chrysler Corp's board of directors decided to liquidate Chrysler because Chrysler was not...
Question Completion Status: QUESTION1 Alpha Corporation owns 100 percent of Beta Company, and Beta owns 80 percent of Gamma, Inc, all of which are domestic corporations. There were no excess allocation values at the date of acquisition of the subsidiaries. Information for the three companies for the year ending December 31, 2018 follows: Alpha 300, Beta Gamma 100, Separate company net income Gross profit from intra-entity transfers of inventory (included in operating income above). The goods have not yet been...
12) Isabella owns all 100 shares of Finch Corporation's stock, valued at $100,000. Abigail owns property that has a $15,000 adjusted basis and a $100,000 FMV. Abigail contributes the property to Finch Corporation in exchange for 100 shares of newly issued Finch stock. Does Sec. 351 apply to Abigail's exchange? What is the amount of her realized gain or loss? How much is recognized?
42. Halperin Corporation owns stock of Leon Corporation. For Halperin and Leon to qualify for the filing of consolidated returns, at least what percentage of Halperin's total voting power and total value of stock must be directly owned by Leon? A) Total voting Total Value of power stock 51% 51% B) Total voting Total Value of power stock 51% 80% C) Total voting Total Value of power stock 80% 80% Total voting power 80% Total Value of stock 51% 43....
42. Halperin Corporation owns stock of Leon Corporation. For Halperin and Leon to qualify for the filing of consolidated returms, at least what percentage of Halperin's total voting power and total value of stock must be directly owned by Leon? A) Total voting power 51% Total Value of stock S1% B) Total voting Total Value of power 51% stock 80% C) Total voting Total Value of stock power 80% 80% D) Total voting Total Value of stock 51% power S0%...
EXHIBIT 16-6 Stock Ownership and Dividends Received Deduction Percentage | Receiving Corporation's Stock Ownership in Distributing Corporation's Stock Less than 20 percent At least 20 percent but less than 80 percent 80 percent or more Dividends Received Deduction Percentage 50% 65 100 * To qualify for the 100 percent dividends received the receiving and distributing corporations must be in the same affiliated group as described in $1504. The 80 percent ownership requirement is the minimum ownership level required for inclusion...
VERSION A: 2019 ACCT 4210A: IN CLASS EXERCISE: LIQUIDATIONS (5 POINTS) 1. (1 POINT) Which I of the following would not be considered a sufficient reason for Chrysler Corp to liquidate? a Chrysler Corp liquidated when the Securities and Exchange Commission (SEC) began to investigate it for securities fraud b. By Chrysler Corp liquidating and re-forming as a limited liability company, Chrysler will eliminate double taxation c. Chrysler Corp's board of directors decided to liquidate Chrysler because Chrysler was not...
VERSION A: 2019 ACCT 4210A: IN CLASS EXERCISE: LIQUIDATIONS (5 POINTS) 1. (1 POINT) Which I of the following would not be considered a sufficient reason for Chrysler Corp to liquidate? a Chrysler Corp liquidated when the Securities and Exchange Commission (SEC) began to investigate it for securities fraud b. By Chrysler Corp liquidating and re-forming as a limited liability company, Chrysler will eliminate double taxation c. Chrysler Corp's board of directors decided to liquidate Chrysler because Chrysler was not...
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