1 Your long time client John is consideringstarting JMP, Corporation with his twocolleagues, Mary and Peter and would likeyour advice regarding formation. John plansto contribute machinery worth $50,000 for100 shares. Mary plans to contribute $50,000Ofor 100 shares, and Peter plans to contributeprofessional services for 98 shares and $1,000for 2 shares. John has a friend who told themabout Section 351, however, he isn't fully sureif the contributions mentioned above wouldallow them to qualify. John wants to know thefollowing: Are the Section 351 requirementsmet? Explain why or why not? What advicecan you give to him, Mary and Peter? Pleaserespond to this post as though you areaddressing John, therefore, please ensure thetone is professional.

A tax is a charge which a taxpayer has to give to the government as per pre defined tax slabs by the…

Answered: Your long time client John is…

SWFT Individual Income Taxes

43rd Edition

ISBN:9780357391365

Author:YOUNG

Publisher:YOUNG

Chapter20: Corporations And Parterships

Section: Chapter Questions

Problem 46P

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I have answered this question and am looking to see if it is correct. Yvonne and Simon form Ion Corporation. Yvonne transfers equipment (basis of $110,000 and fair market value of $165,000). Simon invests $130,000 of cash. They each receive 100 shares in Ion Corporation, worth $130,000, but Yvonne also receives $35,000 of cash from Ion. Calculate Ion Corporation’s basis in the equipment. In addition, determine Yvonne and Simon’s basis in the Ion stock. Yvonne received cash, Ion Corporation subject to section 351 treatment. The gain which is recognized for Yvonne is the lower of the realized gain and the boot. The realized gain is $55,000 and the boot is $35,000 so the recognized gain for Yvonne is $35,000 Yvonne’s basis of stock is $110,000 Ion’s stock basis is $145,000 Simon’s stock basis is $130,000
Joe, June, and Jim—coworkers—decide that they want to start their own business. Joe has $200,000 to contribute, June has equipment valued at $100,000 (basis = $90,000), and Jim has real estate suitable for the business valued at $200,000 (basis = $110,000). Joe and Jim are each to receive 40 percent of the corporate stock, and June is to receive 20 percent. Joe and June transfer title to their property to the corporation immediately. When Jim tries to transfer title to the real estate to the corporation, several legal errors in the title are discovered, and he is unable to transfer title until the errors are corrected. Correcting the errors takes more than 14 months. In the meantime, the corporation begins operating, renting the building from Jim. In the 15th month, Jim is able to transfer title and receive his stock. Is Jim eligible to use the nonrecognition provisions of Section 351 on this transfer?
Your uncle is ready to retire and head for the hills, so he says to you: “Look, I own 500 shares of stock in Startup, Inc. I’m ready to cash out, so I’ll sell it to you for the very same $25,000 I paid for it back in 2012. And, by the way, it’s qualified small business stock, so you’re completely protected on the downside – even if the company went under, you would get 100% tax cushion for the loss! What do you say…???” On its face, what’s wrong with this offer?
Michael has decided to retire from his business and pass the business on to his oldest child, Taylor. He does not want the value of his shares to grow over time. Michael’s shares have an ACB and PUC of $200 and a FMV of $300,000. He plans to use an estate freeze using Section 86. If Michael plans only to take shares as consideration for the exchange, describe the shares that he’ll take as exactly as you can. The type of shares, what happens to their value over time, their attributes such as ACB/PUC/FMV.
Missy owns all 100 shares of Sand Corporation stock having a $1.15 million FMV. Her basis in the stock is $450,000. Sand'sE&P balance is $700,000. Peter would like to purchase the stock but wants only the corporation's non-cash assets valued at $850,000. Peter is willing to pay $850,000 for these assets. How would your answer to Part a change (if at all) if Sand first redeems 25 shares of Missy 's stock for $300,000 and then Peter purchases the remaining 75 shares from Missy for $850,000? Missy will recognize of on her sale of 75 sharos of Sand Corporation stock to Peter. She will recognize an additional of Jon the redemption of her remaining shares by Sand.
Rebecca holds 100 shares of Gotchas stock that she purchased for $1,000 sev- eral years ago. In a merger of Gotchas into Solis, Inc., Rebecca exchanges her 100 Gotchas shares for 1,000 Solis shares and $500. Gotchas is valued at $40 per share and Solis at $3.50 per share. Prepare your solution using spreadsheet software such as Microsoft Excel. What is Rebecca’s realized and recognized gain/loss from the reorganization? What is Rebecca’s basis in her Solis stock?
PP, RR and SS are new CPA’s and are to form a partnership. PP is to contribute cash of P50,000 and his computer originally costing P60,000 but has a second-hand value of P25,000. RR is to contribute cash of P80,000. SS, whose family is selling computers, is to contribute cash of P25,000 and a brand-new computer with a regular selling price of P60,000 but which cost is P50,000. Partners agree to share profits equally. The capital balances upon formation are: PP RR SSa. P 75,000 P80,000 P85,000b. P110,000 P80,000 P75,000c. P 80,000 P80,000 P80,000d. P 83,333 P83,333 P83,334
Required information [The following information applies to the questions displayed below.] On January 1, year 1, Dave received 1,100 shares of restricted stock from his employer, RRK Corporation. On that date, the stock price was $26 per share. On receiving the restricted stock, Dave made the 83(b) election. Dave's restricted shares will vest at the end of year 2. He intends to hold the shares until the end of year 4 when he intends to sell them to help fund the purchase of a new home Dave predicts the share price of RRK will be $46 per share when his shares vest and will be $49 per share when he sells them. Assume that Dave's price predictions are correct and answer the following questions: (Leave no answers blank. Enter zero if applicable. Round your final answer to the nearest whole dollar value. Enter all amounts as positive values.) a. What are Dave's taxes due if his ordinary marginal rate is 32 percent and his long-term capital gains rate is 15 percent? Taxes Due Grant date…
Bill, Bob, and Bo, are partners in the Trendy Company, a retailer of inexpensive kids' wear. They share profits and losses in a 1:4:5 ratio and have decided to expand their business territory. They have agreed to admit Burt to the partnership for a cash investment. Their capital balances are currently P60,000, P100,000, and P140,000, respectively. Burt has been offered a 15% interest in the firm for P130,000. Assuming Burt takes the offer, the entry to record his investment in the partnership includes a: a. credit to gain on sale of partnership interest for P85,000 b. debit to Burt, capital for P45,000 c. credit to Burt, capital for P45,000 d. debit to cash for P130,000
Amy and Jeff Barnes are going to operate their florist shop as a partnership or as an S corporation. After paying salaries of $45,000 to each of the owners, the shop’s earnings are projected to be about $60,000. The earnings are to be invested in the growth of the business. What would you advise them as to which of the two entity forms they should select.
Craig owns a piece of land that he'd like to use in a new business. He will transfer the land into a newly formed corporation using Section 85. The land has an ACB of $2,000 and a FMV of $11,000. If he takes back a note payable equal to $5,000 on the exchange, and the remaining consideration as shares of the corporation, which of these options includes at least part of the tax consequences? The shares will have an ACB of $0 and a FMV of $11,000 $3,000 capital gain will result $3,000 deemed dividend The shares will have an ACB of $2,000 and a FMV of $8,000
Craig owns a piece of land that he'd like to use in a new business. He will transfer the land into a newly formed corporation using Section 85. The land has an ACB of $2,000 and a FMV of $11,000. If he takes back a note payable equal to $5,000 on the exchange, and the remaining consideration as shares of the corporation, which of these options includes at least part of the tax consequences? OThe shares will have an ACB of $0 and a FMV of $11,000 $3,000 capital gain will result $3,000 deemed dividend OThe shares will have an ACB of $2,000 and a FMV of $8,000

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