Question
HoldCo has three subsidiaries, Goes Down Easy that owns liquor stores, Chocaholic which makes candy, and Eastface which makes clothing. The shareholders of Hold Co
HoldCo has three subsidiaries, Goes Down Easy that owns liquor stores, Chocaholic which makes candy, and Eastface which makes clothing. The shareholders of Hold Co are Alice, Bernie and Yamoto. Dave Disruptor buys Yamoto's shares in HoldCo for $500,000. He immediately informs the other shareholders that they are not running the company properly, especially the liquor stores. He promises to disrupt operations unless they put him in charge of HoldCo. Alice suggests to Bernie that they need to get rid of Disruptor and they decide to offer him the shares in Goes Down Easy in exchange for all his shares in HoldCo. After lengthy negotiations of two years an agreement is reached. HoldCo transfers all the shares of Goes Down for Disruptors shares in HoldCo. A valuation by an outside firm has placed the value of Goes Down at $1.2 million and a similar value is given to the shares of Hold Co surrendered by Disruptor. HoldCos basis in the shares of Goes Down was $300,000. 1) Does Disruptor have gain or loss on this exchange, Yes or No? 2. What is Disruptors basis and holding period in the Goes Down shares received as part of the deal? 3 How much gain or loss is recognized by Hold Co on the transfer of the Goes Down shares to Disruptor? 4. What type of a transaction is this?
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