In: Finance
Section 351 Problem – Please give the tax affects to both the shareholder and corporation, including any gains/losses and the basis of both the shareholders in their stock and the corporation in the assets.
Total of 5 shareholders - All assets and liabilities were given during the incorporation:
Shareholder 1 gave $100,000 in cash for 20% ownership/shares.
Shareholder 2 gave a book binding equipment FMV $110,000, basis 30,000 and received $10,000 in cash plus 20% ownership/shares.
Shareholder 3 gave a building FMV $350,000, basis $100,000, and also the company took the building with a mortgage note of $250,000, for 20% ownership/shares.
Shareholder 4 gave paper inventory FMV $60,000, basis $55,000, plus a delivery truck FMV 40,000, basis $50,000 and received 20% ownership/shares
Shareholder 5 gave a printing press FMV $50,000, basis $30,000, plus copyrights FMV $60,000, basis $30,000 for 20% ownership/shares plus $10,000 in cash.
Total Ownership in the company | $ 500,000.00 | |||||||||
Particulars | Percentage of Shareholding | Received Ownership | Cash | Total | Surrender value to the corporate | If sold in the market | Basis of Asset | Gain/ Loss( Shareholder) | Gain/ Loss( Corporation) | |
SH 1 | 20% | $ 100,000.00 | $ - | $ 100,000.00 | $ 100,000.00 | $ - | $ - | Nil | Nil | |
SH 2 | 20% | $ 100,000.00 | $ 10,000.00 | $ 110,000.00 | $ 110,000.00 | $ 110,000.00 | $ 30,000.00 | $ 80,000.00 | Nil | |
SH 3 | 20% | $ 100,000.00 | $ 100,000.00 | $ 350,000.00 | $ 350,000.00 | $ 100,000.00 | $ - | $ 250,000.00 | ||
SH 4 | 20% | $ 100,000.00 | $ 100,000.00 | $ 100,000.00 | $ 100,000.00 | $ 105,000.00 | $ (5,000.00) | |||
SH 5 | 20% | $ 100,000.00 | $ 10,000.00 | $ 110,000.00 | $ 110,000.00 | $ 110,000.00 | $ 60,000.00 | $ 50,000.00 | $ - |