Question: C owns all of the stock of Z Corporation, which is worth $1 million. Z wants to acquire land worth $75,000 from D. C proposes
C owns all of the stock of Z Corporation, which is worth $1 million. Z wants to acquire land worth $75,000 from D. C proposes to transfer $1.00 of cash to Z at the same time D transfers the land to Z. Each C and D will receive stock.
a.
This is not a good Section 351 transaction. D could recognize loss and Z Corporation will take a higher carry-over basis from D.
b.
This is a good Section 351 transaction since C is transferring de minimus amount of property per regulation 1.351(a)(1)(ii).
c.
Neither of the above.
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To analyze this problem lets delve into Section 351 of the Internal Revenue Code IRC and related regulations Section 351 Overview Section 351 allows t... View full answer
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