2. Under IRC Section 311(b)(2), when a corporation distributes a property, subject to a liability, or the
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Question:
2.
Under IRC Section 311(b)(2), when a corporation distributes a property, subject to a liability, or the shareholder assumes the obligation of the distributing corporation, the fair market value (FMV) of the property is at least equal to the amount of the liability.
• Assume your client made a non-liquidating distribution with FMV exceeding its adjusted basis.
• What are the potential tax effects to the distributing company (client) and the receivers (shareholders)?
• Propose a plan in which you mitigate the potential tax impact on your client and the shareholders.
Related Book For
Canadian Income Taxation planning and decision making
ISBN: 9781259094330
17th edition 2014-2015 version
Authors: Joan Kitunen, William Buckwold
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