Question
Tonya contributes $150,000 to Swan, Inc., for 80% of the stock. In addition, she loans Swan $600,000. The maturity date on the loan is 5
Tonya contributes $150,000 to Swan, Inc., for 80% of the stock. In addition, she loans Swan $600,000. The maturity date on the loan is 5 years and the interest rate is 3%, the same as the Federal rate. Which of the following statements are correct?
a.If the loan is not reclassified as equity, Swan can deduct interest expense annually of $18,000, and Tonya includes in gross income annually interest income of $18,000.
b.If the loan is reclassified as equity, Swan claims no interest deduction, and Tonya recognizes no income.
c.If the loan is reclassified as equity, Swan qualifies for a deduction of $600,000 when the loan is repaid, and Tonya receives dividend income of $600,000 (assuming that Swan's earnings and profits are at least $600,000).
d.Only "If the loan is reclassified as equity, Swan qualifies for a deduction of $600,000 when the loan is repaid, and Tonya receives dividend income of $600,000 (assuming that Swan's earnings and profits are at least $600,000)" and "If the loan is not reclassified as equity, Swan can deduct interest expense annually of $18,000, and Tonya includes in gross income annually interest income of $18,000".
e."If the loan is reclassified as equity, Swan qualifies for a deduction of $600,000 when the loan is repaid, and Tonya receives dividend income of $600,000 (assuming that Swan's earnings and profits are at least $600,000)", "If the loan is notreclassified as equity, Swan can deduct interest expense annually of $18,000, and Tonya includes in gross income annually interest income of $18,000", and "If the loan is reclassified as equity, Swan claims no interest deduction, and Tonya recognizes no income".
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