Question
Ridge Development Group is formed on June 1st by John Parks and Sue Jones to operate as a calendar-year, accrual-basis company that develops and markets
Ridge Development Group is formed on June 1st by John Parks and Sue Jones to operate as a calendar-year, accrual-basis company that develops and markets land to customers. John will contribute land with a fair market value of $1,000,000, an adjusted tax basis of $650,000, and a $400,000 nonrecourse bank loan incurred to purchase the land, for an interest in the company. The land was purchased by John three years ago and has been held as an investment. Sue will contribute shares of stock in Frontier Corporation with a fair market value of $200,000 and an adjusted tax basis of $125,000 and shares of stock in Yukon Corporation with a fair market value of $200,000 and an adjusted tax basis of $210,000, for an interest in the company. Sue purchased both blocks of stock 15 months ago as an investment.
If Ridge Development Group is organized as a corporation, then John will receive 58 percent of the shares of stock for his interest and Sue will receive 42 percent of the shares of stock for her interest, after factoring in Ridge Developments deferred tax liability. Alternatively, if organized as a limited liability company taxed as a partnership, then John will receive a 60 percent interest and Sue a 40 percent interest in Ridge Development Group.
Ridge Development Group (Ridge) then proceeded to sell 30 percent of the land for $350,000 on October 20th, all of the shares of stock in Frontier Company for $215,000 on December 10th, and incurred selling and administrative expenses of $50,000 (all related to land sale), which is paid in cash before the end of the year. Ridge also distributed a total of $90,000 to John and Sue based on their proportional ownership on December 20th. Both John and Sue are single, between the ages of 40 50, with no dependents, and each has wages of $110,000 from outside sources. Assume the current year corporate and individual tax rates and refer to the Qualified Dividends and Capital Tax Worksheet, Form 8960 (Net Investment Income Tax) and Form 8959 (Additional Medicare Tax) for the calculation of taxes.
Please see the case requirements below.
1.Prepare a schedule calculating the initial tax basis for John and Sue for the ownership interest in Ridge Development Group when it is formed as a corporation (stock basis). What is the holding period for John and Sue? [Complete in Excel showing all your work.]
2.Will John or Sue be required to recognize any gain on the exchange of their property for stock in the corporation? [Document in Excel or Word Make sure to cite references supporting the conclusion.]
3.Prepare the initial and year-end U.S. GAAP and tax balance sheets for Ridge Development Group when it is formed as a corporation. Also, prepare the U.S. GAAP and tax income statements for the corporation. Note: You will have to calculate the deferred tax liability, following ASC 805-740-25-3, Business Combinations and Income Taxes, and ASC 740-10-25, Income Taxes, at the time of the formation (assume a 21 percent tax rate) and adjust the deferred tax liability at year-end. The stock ownership is 58 percent for John and 42 percent for Sue. [Complete in Excel showing all your work.]
Balance Sheet Hints: Remember that a U.S. GAAP Balance Sheet is at FMV while a Tax Balance Sheet is at carryover basis. Use the above references of ASC to help you with the deferred tax liability calculation. Also, remember that the deferred tax liability is the resulting tax liability that appears on the financial statement.
Income Statement Hints: On the U.S. GAAP Income Statement, after calculating income before taxes remember that your federal tax expense / benefit must consider both current and deferred taxes. For the deferred taxes, you will need to calculate the ending deferred tax liability for the ending balance sheet the difference in the beginning and ending will be the expense / benefit on the income statement. On the Tax Income Statement, you will need to use the rate schedule in calculating the tax.]
4.If Ridge Development Group was organized as a corporation, then identify the different types of taxes that apply and analyze the tax implications for the entity and stockholders (John and Sue). More specifically, calculate the federal tax liability that would apply at the entity level and individual level (this includes income tax and net investment income tax). Is there any change in the shareholders stock basis? [Complete in Excel showing all your work.]
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