Question
GoldCo, a U.S. corporation, incorporates its foreign branch in an IRC 351 exchange, creating GreenCo, a wholly owned foreign corporation. GoldCo transfers inventory with a
GoldCo, a U.S. corporation, incorporates its foreign branch in an IRC 351 exchange, creating GreenCo, a wholly owned foreign corporation. GoldCo transfers inventory with a fair market value of $250 and adjusted basis of $50 and a building with a fair market value of $900 and adjusted basis of $950 to GreenCo in exchange for its stock. GreenCo uses these assets in carrying on its trade or business outside the U.S. What gain or loss, if any, does GoldCo recognize as a result of this transaction?
a. $50 loss.
b. No gain or loss.
c. $100 gain.
d. $150 gain.
e. $200 gain.
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