Sales Having a Tax-Avoidance Purpose - Loss Recognition Is Restricted

question 21

Short Answer

Sales having a tax-avoidance purpose - Loss recognition is restricted where property is transferred to the corporation in a Sec.351 transaction or capital contribution after a date two years before the date that the corporation adopts a plan of complete liquidation.Tax avoidance is inferred in these situations unless the corporation uses the property in its trade or business.
A less-often encountered situation involves distributions or sales of a subsidiary corporation's stock.A corporation can elect under Sec.336(e)to treat the sale,exchange,or distribution of a subsidiary's stock as a disposition of all the subsidiary's assets,resulting in no gain or loss being recognized on the sale,exchange,or distribution of the stock.

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Definitions:

Discount Period

The time frame in which a payment can be made at a reduced rate from the total invoiced amount, typically to encourage early payment.

Periodic Inventory System

An inventory accounting system where updates are made on a periodic basis, not continuously.

Discounts Lost

Represents the extra amount paid by a buyer above the early payment discount price, due to missing the discount period.

Partial Payment

A payment that is made towards a debt or invoice that is less than the full amount owed at the time of payment.