Questions from Federal Taxation

Q: When does the distributing corporation recognize gain or loss on the distribution

When does the distributing corporation recognize gain or loss on the distribution of stock or securities of a controlled corporation to its shareholders?

Q: What is a recapitalization? What types of recapitalizations are nontaxable?

What is a recapitalization? What types of recapitalizations are nontaxable?

Q: Jerry transfers property with a $28,000 adjusted basis and

Jerry transfers property with a $28,000 adjusted basis and a $50,000 FMV to Texas Corporation for 75 shares of Texas stock. Frank, Jerry’s father, transfers property with a $32,000 adjusted basis and...

Q: In a family corporation, how can a recapitalization be used to

In a family corporation, how can a recapitalization be used to transfer voting control tax-free from a retiring senior generation to an upcoming junior generation?

Q: Explain why a transaction might satisfy the letter of Sec. 368

Explain why a transaction might satisfy the letter of Sec. 368 for a reorganization yet fail to be treated as a reorganization.

Q: Which types of reorganizations (acquisitive, divisive, and other)

Which types of reorganizations (acquisitive, divisive, and other) permit the carryover of tax attributes from a target or transferor corporation to an acquiring or transferee corporation?

Q: What restrictions are placed on the acquisition and use of a loss

What restrictions are placed on the acquisition and use of a loss corporation’s tax attributes?

Q: Explain why Sec. 382 will not be an obstacle to the

Explain why Sec. 382 will not be an obstacle to the use of NOL carryovers following an acquisition if the value of the old loss corporation is large relative to its NOL carryovers.

Q: What is a plan of reorganization? Does such a plan need

What is a plan of reorganization? Does such a plan need to be reduced to writing?

Q: Why do some taxpayers secure an advance ruling for a proposed reorganization

Why do some taxpayers secure an advance ruling for a proposed reorganization transaction?