Question

Affiliated & Related Corporations. Allotastock, Inc. (or “A”) is a corporation that engages in business and also owns stock in various other corporations. On January 1, 2018, A’s stock holdings are as follows:

• A holds 85,132 common shares of Burgers, Inc. (or “B”), which has 100,000 total common shares outstanding and no preferred shares;
• A holds 10,000 preferred shares of Cola, Inc. (or “C”), which are worth $100 per share and represent all preferred shares from C (C also has 10,000 common shares outstanding which are worth $8 a share, none of which are owned by A);
• A holds 200 common shares in Dill, Inc. (or “D”) and D has 1,000 common shares outstanding and no preferred shares.

Assume all common shares are voting shares and all preferred shares are non-voting shares. In order to correctly answer the questions below, you will need to identify Affiliated Groups and Related Groups and apply the attribution rules. Unless otherwise stated below, assume the stock ownership does not change during the entire 2018 tax year.

1. What is the minimum number of tax returns that must be filed by A, B, C and D? What is the maximum?

2. What is the maximum combined dollar amount of all Sec. 179 deductions for A, B, C and D in 2018? What is the minimum?

c. Do your answers to a and b above change if A sold 20,000 of the B common shares on July 1, 2015 to an independent third party (thus ending the year with 65,132 B shares)?

Please answer Question "C" only

Answer 1

(C) If A sold 20,000 of the B common shares on July 1, 2015 to an independent third party (thus ending the year with 65,132 B shares,

It doesn't change anything since A still owns more than 50% of the shares,.So it is considered as a related party still and since it sold shares 20,000 shares it can no longer be an affiliated group.

(65,132/100000*100 = 65.132%)

Therefore,

Answer for above questions doesn't change, even if A sold 20,000 of the B common shares on July 1, 2015 to an independent third party.

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