Question
Q1- The stock of JH corporation is owned 20% by Joe, 30% by Joes father, 30% by Joes mother, and 20% by Joes uncle. Joe
Q1- The stock of JH corporation is owned 20% by Joe, 30% by Joes father, 30% by Joes mother, and 20% by Joes uncle. Joe sold the property at $1,000 with adjusted basis of $1,400. Provide federal income tax consequence(s).
Q2- JH Inc is formed in Germany. JH Inc has two wholly owned subsidiaries, Joe Inc, and Han Inc, formed in South Korea and the US, respectively. Joe loaned $100M to Han at 5% per quarter. What would be potential tax issues (at least two) that the IRS could raise in relation to the intercompany loan provided? Also, provide a solution to mitigate the issue(s).
Q3- JH Inc is formed in New York. JH Inc has two wholly owned subsidiaries, Joe Inc, and Han Inc, formed in Michigan and Ohio, respectively. Joe loaned $100M to Han at 5% per quarter. What would be potential tax issue(s) (at least two) that New York, Michigan, and/or Ohio could raise in relation to the intercompany loan provided? Also, provide a solution to mitigate the issue(s).
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