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What type of reorganization is affected in each of the following independent transactions? Type A reorganization Type B reorganization Type C reorganization Spin-off, Split-off or

What type of reorganization is affected in each of the following independent transactions?

Type A reorganization

Type B reorganization

Type C reorganization

Spin-off, Split-off or Split-up under 355 - Specify which type of 355 reorganization

Taxable transaction

A. Flower Corporation is owned by Carry and Kim. All of Carrys stock (FMV $200,000) is exchanged for $200,000 in bonds. Kim exchanges no stock in the transaction.

B. Green Corporation transfers 20% of its voting stock to Brown Corporations shareholders in exchange for 60% of Browns common stock and 90% of its preferred stock. Green acquired 30% of Browns common stock three years ago in a taxable transaction. Brown becomes a subsidiary of Green.

C. Solar currently operates nine lines of business that have been in existence for ten years. To protect its assets from possible lawsuits, Solar transfers each division to a newly formed corporation in exchange for all of the stock of the new corporation. Solar distributes the stock in the nine new corporations to its shareholders in exchange for 45% of their stock in Solar.

D. Bark Corp. and Wood Corp. contribute all of their assets to Tree Corporation in exchange for all of Trees stock. Bark and Wood distribute the Tree stock to their shareholders in exchange for their stock in Bark and Wood. The exchange completes the liquidation of Bark and Wood and each ceases to exist.

E. Pear Corporation wishes to join forces with Plum Corporation. Plum has more name recognition with consumers so Pear would like Plum to be the surviving corporation. Pear transfers all of its assets and only liabilities associated with its real estate to Plum for 45% of Plums voting. Pear distributes the Plum stock to its shareholders in exchange for their Pear stock. Pear then liquidates.

F. Racket Corporation and Laocoon Corporation create Raccoon Corporation. Racket transfers $600,000 in assets for all of Raccoons common stock. Racket distributes its remaining assets ($300,000) and the Raccoon common stock to its shareholder, Mia, for all of her stock in Racket (adj. basis $950,000) and then liquidates. Laocoon receives all of the Raccoon preferred stock for its $400,000 of assets. Laocoon distributes its remaining assets ($300,000) and the Raccoon prefereed stock to its shareholder, Carlos, for all of his stock in Laocoon (adj. basis $200,000) and then liquidates.

G. Ocelot Corporation is merging into Tiger Corporation under state law requirements. Ocelot transfers assets with a fair market value of $300,000 to Tiger. Ocelot receives 30,000 shares of Tiger stock, with a fair market value of $100,000 and $200,000 cash. Ocelot transfers the Tiger stock, $200,000 cash, and all of its liabilities ($50,000) to its shareholder, Van in exchange for all of his Ocelot stock (adj. basis $100,000). Ocelot then liquidates.

H. Xian Corporation and Win Corporation would like to engage in a tax-free reorganization. To that end, Win transfers 90% of its common stock and all of its nonvoting preferred stock, in exchange for 40% of Xians common stock and 20% of its nonvoting preferred stock. Win then distributes the Xian stock, common and nonvoting preferred, to its shareholders.

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