Question
T Corp (T) has assets with fair market value of $210 and $150 adjusted basis. T also has an account payable of $10. T is
T Corp (T) has assets with fair market value of $210 and $150 adjusted basis. T also has an account payable of $10. T is wholly owned by Abby (basis $100; value $200). P Corp (P) is an unrelated entity and has a wholly owned subsidiary, Sub Inc. (S). Ps basis in S is $0. P Corp proposes to acquire Ts assets and liabilities under the following alternative transactions. In each case, please determine the tax consequences for each party, unless noted otherwise. T transfers all of its assets and liabilities to P in exchange for $200 worth of Ps voting stock and then liquidates. Immediately thereafter, P transfers all of the assets and liabilities received from T to S for additional new stock.
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