In a liquidating distribution, Ryan Inc distributes land to its shareholders. Ryan Inc acquired the land 3 years ago in a §351 transfer. Ryan Inc distributes land with FMV of $1,800,000, adjusted basis of $400,000 pro-rata to its two individual shareholders Adama and Brent. Adam and Brent do not get along and are not related to each other. Adam (80%) owner has stock basis of $87,000. Brent (20%) owner has stock basis of $20,000.
a. What is the tax result to Ryan Inc on the distribution?
b. What is the tax result (including basis of the property received) to Adam?
c. What is the tax result (including basis of the property received) to Brent?
Ryan Inc. |
|
Fair market value of the land |
1800000 |
Less: Adjusted basis |
400000 |
Profit on sale of land |
1400000 |
Ryan Inc. is liable to pay tax on the profit of distribution of land to its individual shareholders at FMV.
Adam |
|
Share of Adam |
80% |
Share of land of Adam |
1440000 |
(1800000 x 80%) |
|
Less: Cost basis of stock |
87000 |
Profit of Adam |
1353000 |
Thus, Adam is liable to pay tax on the profit of $1353000.
Adam |
|
Share of Brent |
20% |
Share of land of Brent |
360000 |
(1800000 x 80%) |
|
Less: Cost basis of stock |
20000 |
Profit of Brent |
340000 |
Thus, Brent is liable to pay tax on the profit of $340000.
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