For this Command measurement the mixed holding of NewCo stock by all four transferors taken in general does utilize.
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(6) A longtime professional medical expense strategy needs to be applicable to all retirements of lined eligible staff in a calendar yr.
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There could be other issues relating to A/R and also a/P, but those would rely upon how the deal was structured.
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Just need a fact Verify on the right treatment of a transaction. My consumer is the vast majority owner in four entities (C-Corps) that agreed to contributed belongings and liabilities to a brand new C-Corp (NewCo). A number of the entities experienced liabilities in excessive of assets. However, in accordance with § 351 and § 357, we addressed this as tax free of charge Trade and did not report any obtain as being the 4 entities received no cash proceeds and retained both control and retained Major liability to the transferred liabilities. I just bought a contact from your NewCo CPA expressing they were likely to report a stage up in basis to FMV within the NewCo tax return and was questioning why we didn't report a obtain.
I think The solution here is by business but please proper me if I'm click here Completely wrong. For uses on the Sec. 357 obtain calc, I believe that is done on somebody firm basis, suitable.
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