What are the tax consequences of this liquidation to Parent Corp, Ultra Corp and Sub Corp?

SWFT Corp Partner Estates Trusts
42nd Edition
ISBN:9780357161548
Author:Raabe
Publisher:Raabe
Chapter7: Corporations: Reorganizations
Section: Chapter Questions
Problem 43P
icon
Related questions
Question
Sub Corporation is owned 80% by Parent Corporation and 20% by Superior Corp, a wholly
owned subsidiary of Parent Corp. Sub Corp has three assets: Equipment FMV $80,000, AB
$56,000; Inventory FMV $145,000, AB $110,000; Land FMV $175,000, AB $200,000.
Sub adopts a formal plan of liquidation and immediately thereafter distributes its assets to
Parent and Superior. Superior receives the Equipment and Parent receives the remainder of
the assets. Parent's adjusted basis in its Sub Corporation stock was equal to $240,000 and
Superior's adjusted basis in its Sub stock was equal to $60,000. Parent Corp and Superior
had acquired their Sub Corporation stock six years prior to its liquidation.
What are the tax consequences of this liquidation to Parent Corp, Superior Corp and Sub
Corp?
Sub Corporation is owned 50% by Parent Corporation and 50% by Ultra Corp, a wholly
owned subsidiary of Parent Corp. Sub Corp has three assets: Equipment FMV $55,000, AB
$36,000; Inventory FMV $145,000, AB $110,000; Land FMV $200,000, AB $220,000. Sub
adopts a formal plan of liquidation and immediately thereafter distributes its assets to Parent
and Ultra. Ultra receives the Land and Parent receives the remainder of the assets. Parent's
adjusted basis in its Sub Corporation stock was equal to $215,000 and Ultra's adjusted basis
in its Sub stock was equal to $215,000. Parent Corp and Ultra had acquired their Sub
Corporation stock six years prior to its liquidation.
What are the tax consequences of this liquidation to Parent Corp, Ultra Corp and Sub Corp?
Transcribed Image Text:Sub Corporation is owned 80% by Parent Corporation and 20% by Superior Corp, a wholly owned subsidiary of Parent Corp. Sub Corp has three assets: Equipment FMV $80,000, AB $56,000; Inventory FMV $145,000, AB $110,000; Land FMV $175,000, AB $200,000. Sub adopts a formal plan of liquidation and immediately thereafter distributes its assets to Parent and Superior. Superior receives the Equipment and Parent receives the remainder of the assets. Parent's adjusted basis in its Sub Corporation stock was equal to $240,000 and Superior's adjusted basis in its Sub stock was equal to $60,000. Parent Corp and Superior had acquired their Sub Corporation stock six years prior to its liquidation. What are the tax consequences of this liquidation to Parent Corp, Superior Corp and Sub Corp? Sub Corporation is owned 50% by Parent Corporation and 50% by Ultra Corp, a wholly owned subsidiary of Parent Corp. Sub Corp has three assets: Equipment FMV $55,000, AB $36,000; Inventory FMV $145,000, AB $110,000; Land FMV $200,000, AB $220,000. Sub adopts a formal plan of liquidation and immediately thereafter distributes its assets to Parent and Ultra. Ultra receives the Land and Parent receives the remainder of the assets. Parent's adjusted basis in its Sub Corporation stock was equal to $215,000 and Ultra's adjusted basis in its Sub stock was equal to $215,000. Parent Corp and Ultra had acquired their Sub Corporation stock six years prior to its liquidation. What are the tax consequences of this liquidation to Parent Corp, Ultra Corp and Sub Corp?
Expert Solution
Step 1

For the first scenario, the tax consequences of the liquidation of the Parent Corp, Superior Corp, and Sub Corp are as follows:

 

  1. Sub Corp will recognize a gain or loss on the distribution of its assets to Parent Corp and Superior Corp. In this case, Sub Corp will recognize a loss of $31,000 on the distribution of its inventory and land to Parent Corp and Superior Corp.
  2. Superior Corp will recognize a gain on the distribution of the Equipment from Sub Corp. The amount of the gain will be $20,000, which is the difference between the FMV of the Equipment ($80,000) and Superior Corp's adjusted basis in its Sub stock ($60,000).
  3. Parent Corp will not recognize any gain or loss on the distribution of assets from Sub Corp. Parent Corp will take a basis in the assets received equal to their fair market value.
  4. Sub Corp will be deemed to have sold its assets to Parent Corp and Superior Corp at their fair market value. As a result, Sub Corp will recognize a gain of $31,000, which is the difference between the FMV of the inventory and land ($320,000) and Sub Corp's adjusted basis in those assets ($289,000).
trending now

Trending now

This is a popular solution!

steps

Step by step

Solved in 2 steps

Blurred answer
Knowledge Booster
Accounting for Liquidation of Companies
Learn more about
Need a deep-dive on the concept behind this application? Look no further. Learn more about this topic, accounting and related others by exploring similar questions and additional content below.
Similar questions
  • SEE MORE QUESTIONS
Recommended textbooks for you
SWFT Corp Partner Estates Trusts
SWFT Corp Partner Estates Trusts
Accounting
ISBN:
9780357161548
Author:
Raabe
Publisher:
Cengage
SWFT Comprehensive Volume 2019
SWFT Comprehensive Volume 2019
Accounting
ISBN:
9780357233306
Author:
Maloney
Publisher:
Cengage
SWFT Comprehensive Vol 2020
SWFT Comprehensive Vol 2020
Accounting
ISBN:
9780357391723
Author:
Maloney
Publisher:
Cengage
CONCEPTS IN FED.TAX., 2020-W/ACCESS
CONCEPTS IN FED.TAX., 2020-W/ACCESS
Accounting
ISBN:
9780357110362
Author:
Murphy
Publisher:
CENGAGE L