Questions from Federal Taxation

Q: Explain why an acquiring corporation might be prohibited from using cash as

Explain why an acquiring corporation might be prohibited from using cash as part of the consideration paid in a Type C reorganization.

Q: For the last three years, Lucy and Marvin each have owned

For the last three years, Lucy and Marvin each have owned 50 of the 100 outstanding shares of Lucky Corporation stock. Lucy transfers property having an $8,000 basis and a $12,000 FMV to Lucky for an...

Q: What is the difference between an acquisitive Type C reorganization and an

What is the difference between an acquisitive Type C reorganization and an acquisitive Type D reorganization?

Q: Explain the circumstances in which cash and other property can be used

Explain the circumstances in which cash and other property can be used in a Type B reorganization.

Q: Alpha Corporation purchased for cash a 5% interest in Theta Corporation

Alpha Corporation purchased for cash a 5% interest in Theta Corporation stock. After buying the stock and examining Theta’s books, Alpha’s management wants to make a tender offer to acquire the remain...

Q: In a tender offer, Alpha Corporation wants to exchange its voting

In a tender offer, Alpha Corporation wants to exchange its voting common stock for all of Theta Corporation’s single class of stock. Only 85% of Theta’s shareholders agree to tender their shares. Afte...

Q: Explain the structure of a triangular reorganization. What advantages would a

Explain the structure of a triangular reorganization. What advantages would a triangular reorganization provide the acquiring corporation?

Q: Compare and contrast the requirements for, and the tax treatment of

Compare and contrast the requirements for, and the tax treatment of, the spinoff, split-off, and split-up forms of divisive Type D reorganizations.

Q: Stock in a controlled subsidiary corporation can be distributed tax-free

Stock in a controlled subsidiary corporation can be distributed tax-free to the distributing corporation’s shareholders under Sec. 355. Explain the difference between such a distribution and a divisiv...

Q: Under what circumstances is the distribution of a controlled corporation’s stock or

Under what circumstances is the distribution of a controlled corporation’s stock or securities nontaxable to the distributing corporation’s shareholders? What events trigger the recognition of gain or...