Question
Same facts as MC 4, except XYZ Inc is not a corporation, but is also an LLC. What is the effect, if any, on ABC
Same facts as MC 4, except XYZ Inc is not a corporation, but is also an LLC. What is the effect, if any, on ABC Corps taxable income if XYZ LLC has net operating losses of $400 and QRS LLC has net income of $500? Assume no elections are made.
[For ease of not switching back - MC 4 fact pattern was: ABC Corp. has a wholly owned subsidiary, XYZ Inc. ABC Corp. and XYZ Inc. create QRS LLC under state law, with ABC Corp owning 7 of the 10 ownership units in QRS LLC, and XYZ Inc owns the other 3 units. ]
A. | ABC Corp recognizes $350 of QRS LLCs income, representing 70% of its ownership in QRS LLC. XYZ LLC recognizes $150 of QRS LLCs income, representing 30% of its ownership in QRS LLC, this $150 of gain is offset by the $400 loss, for a net loss of $250 to XYZ LLC. ABC does not recognize this net loss of XYZ LLC. ABCs total income is $350. | |
B. | ABC Corp recognizes $100 of income because QRS LLC is a partnership owned by ABC Corp and XYZ LLC. | |
C. | ABC Corp recognizes $100 of income because it is the sole owner of XYZ LLC and QRS LLC. | |
D. | None of the above, because XYZ LLC is itself an LLC, it cannot own QRS LLC. |
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