Turnip, Inc., a C corporation, distributes a tract of land held as an investment (FMV = $82,000, basis = $22,000) to Chang, its majority (60%) shareholder in exchange for all of his stock. The land is subject to a liability of $100,000. Turnip, Inc. has accumulated E & P of $50,000 and a marginal tax rate of 21%. Chang’s basis in his Turnip’s stock is $20,000 and has an individual marginal tax rate of 32%, a long-term capital gains tax rate of 15%, and $100,000 of other long-term capital gains. The distribution qualifies as a corporate liquidation. Chang has held his stock for three years.
a. What is the tax impact of the distribution to Turnip, Inc?
b. What is the amount of Chang's distribution?
c. What is the tax impact of the distribution to Chang?
d. What is Chang's basis in the land?
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