If Rebecca was one of a group of shareholders who contributed qualifying property to a newly formed C corporation, NewCo, and the group received back 100% of the vote and value of the stock of NewCo what would be the basis in the stock Rebecca received if the property she contributed had a fair market value ("FMV") of $700,000, a tax basis of $400,000 and, in addition to receiving her shares of stock worth $600,000, she also received $100,000 in cash?

XYZ Corp., a closely held C corporation, is contemplating purchasing shares from one of its shareholders, Alice. XYZ is trying to figure out if the transaction will be treated as a redemption, or a dividend. Alice currently owns 100 of the 1,000 shares outstanding. Alice's father owns 50 shares of the XYZ stock. There are no other shareholders that Alice is related to and there are no entities who are shareholders. If XYZ purchases 40 of Alice's shares, under the IRC how many shares will Alice be viewed as owning after the share purchase.

For calendar year 2019 Alpha Corp., a C corporation, earned and reported $10M of taxable income (line 30 of the company's 1120 return). It did not claim any credits on its return. On the last day of 2019 Alpha distributed $4M to its shareholders (all of which for IRC sections 316, 312 and 301 constituted a dividend). The shareholders received the dividend checks on Dec. 31st of 2019. Assume for 2019 that dividend income would be subject to a 20% income tax when the shareholders file their individual 1040 returns. For 2019 Alpha Corp. paid income tax at the top corporate rate of 21%. Looking at both Alpha Corp. and the shareholders what would be the total, or aggregate income tax paid stemming from the $10M of taxable income earned by Alpha Corp. in 2019?

Under IRC section 163(j), enacted as part of the Tax Cuts and Jobs Act of 2017, if, in 2020, Beta Corp. (a C corporation) realized and recognized $8M of business interest income and earnings before interest, tax, depreciation and amortization ("EBITDA") equaled $900M (and assume that this $900M also constituted adjusted taxable income [ or "ATI"] as used in section 163), what is the limit of business interest expense that Beta Corp. could claim as a deduction for its 2020 federal income tax return?

In in a valid IRC section 351 contribution, Shareholder Sadie contributed qualifying property with a basis of $2M, and a FMV of $2.4M. In addition to stock Sadie received a note payable issued by the corporation for $500K. What is Sadie's basis in the stock she received?

For 2019 Omega Corp., a C corporation, prior to any distributions had current earnings and profits ("E&P") of $50M, and accumulated E&P of $400M. At year end 2019 Omega Corp. declared and distributed an IRC section 316 and 301 dividend of $100M. What will Omega Corp.'s accumulated E&P be as of the start of the company's 2020 year?