C and D jointly organize Z Corporation. C transfers properties to Z in exchange for $150 cash and half of Z's stock. D transfers $150 in cash to Z in exchange for the other half of the stock. C's property consists of two parcels, parcel 1 with a basis of $120 and a value of $240 and parcel 2 with a basis of $90 and a value of $60.

a. C has a gain of $120 on parcel 1 which is recognized and a loss of $30 on parcel 2 which is not recognized. C has a basis of $180 in all of the stock based on a basis of $210 in the property transferred in plus $120 in gain realized less $150 in cash received.

b. Under 351 C has a net gain of $90 on the transfer of the two parcels and must recognize that amount of gain because of the $150 cash boot.

c. C's basis in its stock received is the basis of $210 plus $150 gain realized minus $150 cash received or $210.

d. None of the above.

In 2020,the dividends received deduction (DRD) for corporations owning less than 10% of a foreign corporation is:

a.50%

b.65%

c.100%

d.0

e. None of the above