Question
1-list the key statutory requirements that must be met before a corporate formation is tax deferred under 353. 2-what is a substituted basis as it
1-list the key statutory requirements that must be met before a corporate formation is tax deferred under 353.
2-what is a substituted basis as it relates to stock received in exchange for property in a 351 transaction? what is the purpose of attaching a substituted basis to stock recieved in a 351 transaction?
3-why might a corporation prefer to characterize an instrument as debt rather than equity for tax purposes? are the holders of the instrument indifferent as to its characterization for tx purposes?
4-why does the acquiring corporation usually prefer to buy the target corporations assets directly in an acquisition?
5-what are the key differences in the tax law requirements that apply to forward versus reverse triangular mergers?
6-what are the key differences in the tax law requirements that apply to forward versus reverse triangular mergers?
7-in a stock acquisition, why is there a difference between the tax basis of assets held by an acquired corporation and the tax basis of the shares held by a corporate acquirer? why is this difference important?
8-what is the presumption behind the continuity of ownership interest (COI) requirement in a tax deferred acquisition? how do the target shareholders determine if COI is met in a Type A reorganization?
9-compare how a shareholder computers her tax basis in stock received from the acquiring corporation in a straight type A merger versus a type B merger.
10-Explain whether all shareholders receive the same tax treatment in a complete liquidation of a corporation.
11-under what circumstances does a corporate shareholder receive tax deferral in a complete liquidation
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