Parent Corporation has owned all 100 shares of Subsidiary Corporation common stock since 2008. Parent has been

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Parent Corporation has owned all 100 shares of Subsidiary Corporation common stock since 2008. Parent has been in the business of manufacturing and selling light fixtures, and Subsidiary has been in the business of manufacturing and selling light bulbs. Amy and Bill are the two equal shareholders of the Parent stock and have owned their stock since 2008. Amy’s basis in her 50 Parent shares is $80,000, and Bill’s basis in his 50 Parent shares is $60,000. On April 10, 2015, Parent distributes all 100 Subsidiary shares to Bill in exchange for all his Parent shares (which are cancelled). The distribution has a bona fide business purpose. The Subsidiary stock had a $30,000 basis to Parent on the distribution date. At the end of 2015, Parent has $150,000 of E&P. Immediately after the distribution, the FMVs of the Parent and Subsidiary stocks are $3,000 and $1,000 per share, respectively.
a. What are the amount and character of the gain, loss, or income Bill must recognize as a result of Parent’s distributing the Subsidiary stock?
b. What basis does Bill take in the Subsidiary stock?
c. When does Bill’s holding period for the Subsidiary stock begin?
d. Assume instead that Andrew formed Subsidiary in 2011 to manufacture and sell lightbulbs. Andrew sold the Subsidiary stock to Parent for cash in 2013. How would your answers to Parts a–c change?
Common Stock
Common stock is an equity component that represents the worth of stock owned by the shareholders of the company. The common stock represents the par value of the shares outstanding at a balance sheet date. Public companies can trade their stocks on...
Stocks
Stocks or shares are generally equity instruments that provide the largest source of raising funds in any public or private listed company's. The instruments are issued on a stock exchange from where a large number of general public who are willing...
Corporation
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...
Distribution
The word "distribution" has several meanings in the financial world, most of them pertaining to the payment of assets from a fund, account, or individual security to an investor or beneficiary. Retirement account distributions are among the most...
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Federal Taxation 2016 Comprehensive

ISBN: 9780134104379

29th Edition

Authors: Thomas R. Pope, Timothy J. Rupert, Kenneth E. Anderson

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