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6 page accounting essay

06/08/2020 Client: papadok01 Deadline: 24 Hours

  


Liability in a Section 351 Transfer


Sara Sun transferred three properties to Green Construction: an office building, office equipment in that building, and an adjacent parking garage, in a Sec. 351 exchange, as shown in the table below:


attached 


  


The garage and equipment are free of liabilities, but a $110,000 mortgage remains on the office building. Complete calculations and explain your answers to these questions, referencing all applicable sections of the Internal Revenue Code:



  1. If      Green Construction assumes the mortgage, what gains and tax-related      effects would Freeman and Health Innovations sustain?

  2. What      if Green Construction does not assume the mortgage? What      gains and tax-related effects would Sara Sun and Green Construction      sustain?


No hard coding of solutions. 


Submission Requirements



  • Be      sure to discuss and reference concepts taken from the assigned textbook      reading and relevant research.

  • Support      your paper with at least 4-6 tax, scholarly, legislative, or court      references (of which the textbook may be one).

  • Review      the grading rubric to see how you will be graded for this assignment.


Your paper should be 6 pages in length and conform to the APA format. Include at least four scholarly references in addition to the course textbook. 


Chapters 18 & 19 in South-Western Federal Taxation 2019


Redemption Through Use of Related Corporations, 26 USC §304


Narotzki, D., & McCoskey, M. (2018). An attempt to distinguish between a section 351 transfer and a B reorganization. The ATA Journal of Legal Tax Research, 16(1), 17.


Alstadsæter, A., Jacob, M., & Michaely, R. (July 2017). Do dividend taxes affect corporate investment? Journal of Public Economics, 151(C), 74-83.


Assumption of liability, 26 U.S. Code § 357 (n.d.). Retrieved from Thomson Reuters Checkpoint database.


Basis to corporations, 26 U.S. Code § 362 (n.d.). Retrieved from Thomson Reuters Checkpoint database.


Basis to distributees, 26 U.S. Code § 358 (n.d.). Retrieved from Thomson Reuters Checkpoint database.


Complete liquidations of subsidiaries, 26 U.S. Code § 332 (n.d.). Retrieved from Thomson Reuters Checkpoint database.


Definitions relating to corporate reorganizations, 26 U.S. Code § 368 (n.d.). Retrieved from Thomson Reuters Checkpoint database.


Distributions of property, 26 U.S. Code § 301 (n.d.). Retrieved from Thomson Reuters Checkpoint database.

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