Parent Corporation Owns 100% of the Stock of Subsidiary Corporation

question 30

Essay

Parent Corporation owns 100% of the stock of Subsidiary Corporation. The adjusted basis of its stock investment is $100,000. A plan of liquidation is adopted. Subsidiary distributes to Parent assets with a $325,000 FMV and a $275,000 adjusted basis. Subsidiary also distributes liabilities in the amount of $40,000. Subsidiary has a $150,000 E&P balance.
a)What is the amount and character of Subsidiary Corporation's recognized gain or loss on the distribution?
b)What is the amount and character of Parent Corporation's recognized gain or loss on the redemption of the Subsidiary stock?
c)What basis does Parent take in the assets?
d)What happens to parent Corporation's basis in the Subsidiary stock and to Subsidiary's tax attributes?

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Definitions:

Capital Flight

The large-scale exodus of financial assets and capital from a nation due to events such as political or economic instability, reducing the nation's investment capacity.

Net Capital Outflow

The difference between the domestic country's purchase of foreign assets and foreign purchases of the domestic country's assets over a certain period.

Net Exports

The value of a country's total exports minus its total imports, representing the trade balance within a specific period.

Tariffs

Taxes or duties imposed on imported goods to make them more expensive compared to domestic goods, often used to protect local industries.