Which of the following statements is correct with respect to the § 338 election? a. The parent recognizes no gain (loss) as a result of the election. b. The subsidiary corporation makes the § 338 election. c. A qualified stock purchase occurs when a corporation acquires in a taxable transaction at least 80% of the stock (voting power and value) of another corporation within an 18-month period. d. Gain but not loss is recognized by the subsidiary as a result of a deemed sale of its assets.

Which of the following statements is correct with respect to the § 338 election? a. The parent recognizes no gain (loss) as a result of the election. b. The subsidiary corporation makes the § 338 election. c. A qualified stock purchase occurs when a corporation acquires in a taxable transaction at least 80% of the stock (voting power and value) of another corporation within an 18-month period. d. Gain but not loss is recognized by the subsidiary as a result of a deemed sale of its assets.

SWFT Comprehensive Volume 2019

42nd Edition

ISBN:9780357233306

Author:Maloney

Publisher:Maloney

Chapter17: Corporations: Introduction And Operating Rules

Section: Chapter Questions

Problem 43P

See similar textbooks

Similar questions

Hippo Co. is a holding company. It holds all the shares of Opco. Shareholder H holds all the shares of Hippo Co. What should Opco be directed to do prior to its sale in order to minimize taxable capital gains? a. Transfer all assets to Hippo Co. before sale. b. Transfer all shares in Opco to Shareholder H prior to the sale c. Transfer all the shares of Hippo Co. to shareholder H prior to the sale. d. Pay a tax-free dividend to Hippo Co. from Opco prior to the sale
when a new corporation is created from the old subsidiary under provisions of 338, the new corporation may A. adopt any tax year that suits its purposes, limited only by the consolidated return rules. B. Disregard anti-churning rules and use MACRS deprecation for all of the purchased property. C. not have available any net operating loss carryovers from of the old subsidary. D. Do all of the above.
A subsidiary corporation is liquidated under Section 332. Pursuant to its liquidation, the subsidiary distributed property to a minority shareholder. With respect to this distribution, what are the tax consequences to the subsidiary corporation and to the minority shareholder?
Which of the following statements is true related to the conversion of a regular corporation to a limited liability company taxed as a partnership? A. In the conversion of a C corporation to an LLC taxed as a partnership, the transfer of appreciated assets from the liquidating corporations is not taxed at the corporate level. B. The corporation can contribute it's assets and liabilities into the new LLC in exchange for ownership interests. The corporation then distributes the LLC interests to it's shareholders in liquidation of the shareholders corporate stock. C. If the corporation distributes it's assets and liabilities to it's shareholders in liquidation of the new corporation, the shareholders are restricted from contributing these assets into the new partnership. D. The existence of substantially appreciated intangibles and goodwill with little or no tax basis has no consequences when converting a C corporation to an LLC
Which of the following is correct for two companies that want to file a consolidated tax return as an affiliated group?a. One company must hold at least 51 percent of the other company’s voting stock.b. One company must hold at least 65 percent of the other company’s voting stock.c. One company must hold at least 80 percent of the other company’s voting stock.d. They cannot file one unless one company owns 100 percent of the other’s voting stock.
Identify which of the following statements is false. Select one: a. The 50% dividends-received deduction is limited to 50% of the taxable income of the corporation without regard to any NOL deduction, any capital loss carryback, and the dividends-received deduction itself unless the dividends-received deduction produces an NOL. b. Members of an affiliated group can claim a 90% dividends-received deduction for dividends received from other group members that is not subject to a taxable income limitation. c. A corporate dividends-received deduction is not allowed for dividends received on stock held for 40 days. d. All of the above are false.