Summary- The provisions contained in IRC Sec 357 need to be very carefully examined so which the non-taxable standing in the transfer of liabilities to some controlled Company designed underneath Sec 351 will not be jeopardized. In accordance with Sec 351, a transfer of residence to a corporation in Trade for stocks will not trigger the recognition of any achieve or loss delivered the receiver of your shares will right away acquire Charge of the Company.
Roland and bbrown - I stand corrected, nonetheless- will not the obtain be precisely the same and will not the new CPA require the per asset/for each Take note payable data? Sorry for the confusion and glad you and Jon are presenting feedback on this thread. Comment
At first posted by bbrownatl View Publish Okay, so it seems like a acquire really should be acknowledged. Now, one particular further issue. The Businesses transferring all in their property and liabilities have been on the cash foundation of accounting.
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Just require a truth Test on the correct procedure of a transaction. My shopper is majority owner in four entities (C-Corps) that agreed to contributed belongings and liabilities to a fresh C-Corp (NewCo). Some of the entities had liabilities in surplus of assets. However, in accordance with § 351 and § 357, we treated this as tax cost-free Trade and didn't report any get as the four entities gained no cash proceeds and retained both Handle and retained Most important liability around the transferred liabilities. I just obtained website a call in the NewCo CPA declaring they had been likely to report a phase up in basis to FMV to the NewCo tax return and was questioning why we didn't report a attain.
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