Question
Green Corporation owns 100% of the stock of Yellow Corporation (all common) with a basis of $100. Yellow Corporation owns a rental building (its only
Green Corporation owns 100% of the stock of Yellow Corporation (all common) with a basis of $100. Yellow Corporation owns a rental building (its only asset) with a gross FMV of $1,000, subject to a nonrecourse mortgage of $400. Yellow's adjusted basis in this building is $300. Yellow has $200 of E&P. Yellow is on the accrual method of accounting and reports on the calendar year. Yellow Corporation and Green Corporation do not report on a consolidated basis.Yellow Corporation sells its building to ABC Corporation for $600 cash, subject to the debt, pays its tax, and liquidates. What is the character and amounts of realized and recognized gain or loss to all parties, the time of recognition, the transferee's basis in any property received in kind, and any E&P impact
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