Question
Which of the following events as part of an acquisitive reorganization require the target corporation to recognize gain? Assume in all cases that the target
Which of the following events as part of an acquisitive reorganization require the target corporation to recognize gain? Assume in all cases that the target corporation liquidates in the reorganization.
For each case, select if the target corporation is required to recognize gain, and select the reason why
1. Transfer of appreciated target corporation assets in exchange for acquiring corporation stock and short-term notes.
A. No, because excess liabilities assumed by the acquiring company do not affect gain
B. No, liabilities are not tantamount to the receipt of cash
C. No, providing the target corporation distributes the cash to its shareholders
D. No, providing the target corporation distributes the notes to its shareholders
E. No, since the cash is transferred to creditors
F. Yes, because short term notes are boot
G. Yes, because excess liabilities assumed by the acquiring corporation create boot and must be realized
H. Yes, gain is recognized when appreciated assets are transferred
2. Transfer of appreciated target corporation assets in exchange for acquiring corporation stock and the assumption of the target corporation's liabilities.
A. No, because excess liabilities assumed by the acquiring company do not affect gain
B. No, liabilities are not tantamount to the receipt of cash
C. No, providing the target corporation distributes the cash to its shareholders
D. No, providing the target corporation distributes the notes to its shareholders
E. No, since the cash is transferred to creditors
F. Yes, because short term notes are boot
G. Yes, because excess liabilities assumed by the acquiring corporation create boot and must be realized
H. Yes, gain is recognized when appreciated assets are transferred
3. Assume the same facts as in Part b except the amount of liabilities assumed by the acquiring corporation exceeds the adjusted basis of the target corporation assets transferred.
A. No, because excess liabilities assumed by the acquiring company do not affect gain
B. No, liabilities are not tantamount to the receipt of cash
C. No, providing the target corporation distributes the cash to its shareholders
D. No, providing the target corporation distributes the notes to its shareholders
E. No, since the cash is transferred to creditors
F. Yes, because short term notes are boot
G. Yes, because excess liabilities assumed by the acquiring corporation create boot and must be realized
H. Yes, gain is recognized when appreciated assets are transferred
4. Transfer of appreciated target corporation assets in exchange for stock and cash. The target corporation distributes the cash to its shareholders.
A. No, because excess liabilities assumed by the acquiring company do not affect gain
B. No, liabilities are not tantamount to the receipt of cash
C. No, providing the target corporation distributes the cash to its shareholders
D. No, providing the target corporation distributes the notes to its shareholders
E. No, since the cash is transferred to creditors
F. Yes, because short term notes are boot
G. Yes, because excess liabilities assumed by the acquiring corporation create boot and must be realized
H. Yes, gain is recognized when appreciated assets are transferred
5. Transfer of appreciated target corporation assets in exchange for stock and cash. The target uses the cash to pay off its liabilities.
A. No, because excess liabilities assumed by the acquiring company do not affect gain
B. No, liabilities are not tantamount to the receipt of cash
C. No, providing the target corporation distributes the cash to its shareholders
D. No, providing the target corporation distributes the notes to its shareholders
E. No, since the cash is transferred to creditors
F. Yes, because short term notes are boot
G. Yes, because excess liabilities assumed by the acquiring corporation create boot and must be realized
H. Yes, gain is recognized when appreciated assets are transferred
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