Vivian and her daughter Ivy have been working together in a spa called "Viva Bien". Vivian formed the business in 2001 as a sole proprietorship. The business has become very successful over the years and Vivian's tax accountant is recommending that she incorporate the business. Business assets have a fair market value of $550,000 and a basis of $280,000. Vivian would like to give shares of stock to Ivy, because of her participation in the business.

What are the relevant tax issues?